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2025 (3) TMI 2245
Case Laws Income Tax
Cash-deposit source verification requires examination of jewellery sales, jute transactions, commission receipts, and supporting third-party evidence.
Cash-deposit source claims based on jewellery sales, jute and jute-bag sales, and commission receipts require fresh verification where supporting material was not produced earlier or remains insufficient. Jewellery-sale evidence must be examined, while jute transaction samples must be tested with the claimed commission receipts and the nature of underlying transactions. The commission basis requires confirmation from identified persons and supporting documents. The source claims were remitted to the Assessing Officer for fresh verification after providing the assessee adequate opportunity.

2025 (3) TMI 2246
Case Laws Income Tax
Section 14A disallowance fails where investments generate no exempt income during the relevant assessment year.
Section 14A read with rule 8D does not permit disallowance of expenditure where no exempt income was earned during the relevant assessment year. Since the investments did not generate exempt income, no expenditure could be regarded as incurred in relation to income excluded from total income. A CBDT circular supporting disallowance despite the absence of exempt income cannot override the statutory provision or its judicial interpretation. Accordingly, the section 14A disallowance computed under rule 8D was unsustainable and deleted.

2025 (3) TMI 2247
Case Laws Income Tax
Duplicate transaction-statement entries require verification before salary and professional-fee income additions are sustained or recomputed.
Duplicate entries in Individual Transaction Statement data for salary income and professional or technical-fee receipts require verification before additions are sustained. Reconciliation identified corresponding receipts appearing twice, raising the possibility that certain income had been taxed twice. The Assessing Officer must conduct limited verification of the alleged duplication, allow the assessee an opportunity to be heard, and recompute the correct taxable income.

2025 (3) TMI 2248
Case Laws Income Tax
Ineligible charitable expenditure reduces eligible application of income and cannot be separately added to the trust's total income.
Expenditure by a charitable trust for the benefit of a person specified under section 13(3), for which section 11 exemption is unavailable, must be excluded from the expenditure claimed as charitable application of income. It is not to be separately added to total income. Where the resulting net income is absorbed by permissible accumulation, total income remains nil. Interest received on a corpus donation carrying a direction to provide medical assistance to patients recommended by the donor does not alter this computational treatment where the donor is a specified person.

2025 (3) TMI 2249
Case Laws Income Tax
Documentary evidence of sale-agreement receipts rebutted unexplained cash-deposit allegations, leading to deletion of the addition.
Cash-deposit addition for alleged unexplained deposits was unsustainable where documentary material evidenced that the assessee's wife received funds under an agreement to sell, transferred them to the assessee, and the amount was deposited in the bank account. Non-registration and subsequent cancellation of the agreement did not, by themselves, disprove the receipt. In the absence of positive evidence contradicting the explanation, the addition was deleted; only a small balance amount remained unexplained.

2025 (3) TMI 2250
Case Laws Income Tax
Legal representative status requires proof of estate management, intermeddling, or statutory proceedings before an appeal can proceed.
Appeals filed by a purported legal representative of a deceased assessee are maintainable only where the applicant proves management of the deceased's estate, intermeddling with the estate, or that proceedings have been initiated against the applicant as legal representative under the Act. Mere assertion of representative status is insufficient. Without material establishing any of these circumstances, the applicant lacks demonstrated competence to maintain the appeals. Such appeals may be treated as premature, while permitting fresh filing once representative status is substantiated.

2025 (6) TMI 2156
Case Laws Income Tax
Section 153C satisfaction requires identified seized material and assessment-year nexus; generic identical notes invalidate the resulting assessment.
Section 153C requires a valid, actionable satisfaction based on seized material that pertains to the other person and can affect income determination for the relevant assessment year. A consolidated satisfaction note may be used, but it must identify the seized documents, relevant transactions and assessment-year-wise nexus, demonstrating application of mind. An identical generic note that omits these particulars fails the jurisdictional requirement. Such satisfaction is non est in law, rendering the assessment initiated on its basis unsustainable.

2025 (8) TMI 1850
Case Laws Income Tax
Section 153D approval must reflect independent year-wise consideration; mechanical consolidated approval invalidates Section 153C assessments.
Section 153D requires informed, independent approval for each assessee and assessment year before assessments under Section 153C are finalised. Placing only draft assessment orders before the approving authority, while issuing a consolidated approval for multiple years and asserting review of case records, does not demonstrate consideration of the relevant records, seized material and year-specific draft orders. A mechanically issued consolidated approval therefore fails the statutory requirement. The approval covering multiple assessment years was invalid, resulting in the quashing of the Section 153C assessments for the relevant years.

2026 (1) TMI 1665
Case Laws Income Tax
Year-wise satisfaction under Section 153C is essential; a consolidated note invalidates proceedings lacking material for earlier assessment years.
Section 153C requires satisfaction linking seized material to the relevant assessee and each assessment year. A sale agreement dated 28.08.2018 could at most relate to Assessment Year 2019-20 and did not connect with earlier years. Recording one consolidated satisfaction note for Assessment Years 2013-14 to 2019-20, without separate year-wise satisfaction, was treated as insufficient to assume jurisdiction. On that basis, the Section 153C proceedings, consequential notices and assessments for all covered years were described as invalid and quashed in favour of the assessee.

2026 (2) TMI 1462
Case Laws Income Tax
Jurisdictional sanction under reassessment law invalidates proceedings when approval comes from an authority below the prescribed statutory level.
Prior sanction for an order under section 148A(d) and notice under section 148 is jurisdictional and must be obtained from the authority specified under section 151 based on the elapsed period. For assessment year 2016-17, the applicable three-year period, including the COVID-19 relaxation, expired on 30 June 2021. Approval granted on 27 July 2022 therefore required sanction from the higher specified authority under section 151(ii), not the Principal Commissioner. The proviso introduced from 1 April 2023 did not apply to the order and notice issued in July 2022. Sanction by an incompetent authority rendered the reassessment proceedings invalid.

2026 (3) TMI 1746
Case Laws Income Tax
Asset-based condition for extended reassessment period excludes unsupported bogus-purchase allegations, invalidating reassessment and deleting the addition.
Reassessment beyond three years under Section 149(1)(b) requires material showing escaped income of the prescribed threshold represented in the form of an asset. Alleged bogus purchases are revenue items and do not satisfy that condition unless they result in an identifiable asset recorded in the assessee's balance sheet. As no material or allegation established that the purchases created such an asset, the reassessment notice and consequential reassessment were invalid, and the bogus-purchase addition was deleted.

2026 (7) TMI 2015
Case Laws Income Tax
Retrenchment compensation exemption applies to eligible BSNL VRS-2019 ex-gratia payments, with delayed appellate claims entertainable on sufficient cause.
BSNL VRS-2019 ex-gratia compensation is treated as retrenchment compensation eligible for full exemption under Section 10(10B), despite an earlier exemption claim under Section 10(10C). The exemption claim may be raised through a revised computation during appellate proceedings where it was not made in a revised return. Delays in filing first appeals by similarly placed employees may be condoned where lack of awareness, incorrect professional advice and parity with favourable decisions establish sufficient cause. The Assessing Officer must verify eligibility for both assessment years, grant the exemption where due, and determine resulting tax liability or refund.

2025 (12) TMI 1888
Case Laws GST
Movable wind turbine generators make supply and installation services a composite supply rather than an immovable-property works contract.
Wind turbine generators assembled and erected on foundations qualify as movable goods where they can be dismantled, relocated and sold without damage. Applying the tests of nature and object of annexation, intention, functionality, permanency and marketability, attachment to the foundation serves stable and efficient operation rather than beneficial enjoyment of the foundation. Although the foundation remains embedded and immovable, the generators are not permanently annexed to it. Their supply together with associated services therefore constitutes a composite supply, rather than a works contract relating to immovable property.

2026 (6) TMI 1503
Case Laws GST
Authority to seal business premises is challenged after GST search, with respondents directed to answer the writ petition.
The sealing of a tax consultancy office following a search and seizure is challenged on the ground that the Superintendent of State Tax lacked legal authority to seal the premises. The High Court issued notice to the State respondents, returnable within two weeks. As counsel accepted notice for all respondents, no formal notice was required; the petitioner must provide additional writ-petition copies within three working days. No determination on the legality of the sealing has been made at this stage.

PMLA / Black Money
Dated:- 12-8-2026
PTI
Enforcement action under the Prevention of Money Laundering Act concerns allegations that an insolvency professional re-admitted claims earlier rejected as spurious and fraudulent during the Corporate Insolvency Resolution Process. The alleged re-admission altered the Committee of Creditors' composition and facilitated consideration of a resolution plan allegedly submitted for, and funded through an entity controlled by, a company promoter under investigation for diversion of bank-loan funds. Adverse findings reportedly included acting beyond authority by relying on fabricated and improperly submitted material.

Corp. Laws / SEBI / IBC
Dated:- 12-8-2026
PTI
Alleged forgery and misuse of identity-related records are under investigation following operations at Aadhaar centres. Seized materials reportedly include forged birth, educational, residence, caste and citizenship certificates, records bearing forged signatures and seals, and equipment used for Aadhaar updates. Four persons were arrested in two operations for allegedly preparing forged records and using them to update Aadhaar cards. Cases have been registered under relevant provisions of the Bharatiya Nyay Sanhita, with investigation continuing into the extent of the alleged network.

Tariff values for specified imports are substituted under the customs valuation framework, effective 11 August 2026. The prescribed values remain unchanged for crude palm oil, refined and other palm oil, crude and refined palmolein, soybean oil, brass scrap and areca nuts. Tariff values are also prescribed for eligible gold and silver imports, including specified gold bars, coins and findings, and specified silver forms, medallions and coins, subject to the stated exclusions for postal, courier and baggage imports where applicable. These values apply for customs valuation of the covered goods.

Privately placed municipal debt securities may have a face value of either Rs. One Lakh or Rs. Ten Thousand; securities issued at Rs. Ten Thousand must have fixed maturity and no structured obligations, and their exchange trading lot must equal face value. These requirements do not apply to public issues. Pooled finance vehicles or SPVs must implement a two-step escrow arrangement through constituent-municipality accounts and maintain an interest payment account and sinking fund account, including one year's interest obligation throughout the securities' tenure. Permitted credit enhancement includes cash collateral, state program equity, devolutions, guarantees and other suitable structures. Listed municipalities must submit half-yearly unaudited results within 60 days and annual audited results within 90 days, with immediate effect.

DGFT advises heightened vigilance when dealing with two identified Bhutanese firms following a complaint and the absence of substantive responses through diplomatic and administrative channels under the Foreign Trade Policy 2023. Export Promotion Councils, Regional Authorities, ECGC, authorised dealer banks and other stakeholders should conduct comprehensive due diligence, alert trade participants to the concerns, assess transaction risk before providing trade, credit, certification or facilitation support, and report adverse experiences, payment issues or contractual disputes. The advisory is precautionary and seeks to protect Indian exporters and trade stakeholders from potential risks.

Notification No. G.O.Ms.No. 40 Dated:- 20-5-2021 Telangana SGST
Telangana GST corrigendum corrects G.O. Ms. No. 26 under the Telangana Goods and Services Tax Rules, 2017. It replaces the reference to "the proviso" with "the provisos" and changes the period stipulated in paragraph 4 from seven working days to thirty days.

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