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Provisional attachment requires a genuine alienation risk and cannot continue where cash remains in government custody.
Provisional attachment under Section 24(3) requires a demonstrable basis to believe that the person in possession may alienate the benami property during the notice period. Cash already held by the Income Tax Department is unavailable for alienation by the assessee, so attachment cannot be sustained merely on that basis. A challenge to the issuing officer's competence cannot ordinarily be introduced for the first time on appeal where it involves unresolved factual issues, was not raised before the Adjudicating Authority, and no leave was obtained. Fresh attachment may be considered if later circumstances establish the statutory risk of alienation.
Composite letting with customised facilities and continuing services is business income, supporting related deductions and depreciation claims.
Composite letting of industrial premises with tenant-specific customisation, furnishings, repairs, security, housekeeping, parking and other continuing services is treated as business income where it constitutes a structured service operation rather than bare rental exploitation. Operational expenses, employee salaries, directors' remuneration and depreciation connected with that activity are consequently allowable. Compensation paid to tenants for surrendering tenancy rights is deductible as business expenditure where it secures vacant possession, prevents third-party rights and facilitates reletting without creating a capital asset or enduring advantage. Reversal of an earlier tax provision may be excluded from book profit only if the original provision was not allowed as a deduction. MAT credit, unabsorbed depreciation set-off and TDS credit require verification and recomputation under applicable law.
Corporate guarantee disclosure cannot trigger disallowance where no expenditure was debited or claimed as a deduction.
Corporate guarantee disclosed as a contingent liability cannot be disallowed under Section 37(1) where it was neither debited to the profit and loss account nor claimed as expenditure or deduction in the return. Tax-audit reporting alone does not establish an expenditure claim, particularly where the auditor clarifies that the disclosure was inadvertent and the financial statements confirm that the amount appeared only in the notes to accounts. The adjustment was therefore deleted because disallowance under Section 37(1) presupposes a claimed expenditure.
Unexplained cash receipts require source correlation; peak credit cannot automatically restrict additions, requiring fresh determination.
Peak Credit Theory cannot be applied merely because unexplained cash receipts and expenditure exist. Cash receipts omitted from the cash book and not linked to sales, loans, or another explained source remain liable to addition as unexplained cash credits. Expenditure is explained only to the extent its source is traceable to disclosed funds or to undisclosed receipts already taxed; any balance remains unexplained. Deleting a cash-receipt addition after accepting the receipt as unexplained requires supporting reasoning. The deletion and restriction of additions through peak-credit application require fresh determination under these principles.
Associated-enterprise status governs recomputation of transfer-pricing interest adjustments and interest-limitation disallowance for non-convertible debenture lenders.
Associated-enterprise status under Section 92A(2)(c) is foundational to transfer-pricing adjustment of interest on non-convertible debentures and to the interest-limitation disallowance under Section 94B. A revised Form 3CEB filed before the transfer-pricing order identified only one lender as a deemed associated enterprise under the loan-to-assets threshold; Section 92CA(3) prescribes no time limit for such revision. The taxpayer must produce cogent evidence that the remaining lenders were independent enterprises. Transfer-pricing and Section 94B computations require fresh determination after establishing each lender's associated-enterprise status.
Rural advance provisions and Kisan Credit Card interest deductions sustained where certified branch data and long-term finance character remained unrebutted.
Deductions for provisions for bad and doubtful debts on rural advances remain allowable where RBI-certified rural-branch data is unrebutted and the claimed amount falls within the permissible limit. No branch exceeding the relevant population threshold was identified during assessment or remand proceedings, so the disallowance was deleted. Interest on Kisan Credit Card loans qualifies for deduction relating to transfer to a special reserve because annual review does not alter the loans' character as long-term finance. The deduction remains subject to the applicable statutory ceiling, and the related disallowance was deleted.
Reassessment beyond four years fails without disclosure failure and a live nexus to alleged income escapement.
Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons identifying the assessee's failure to disclose fully and truly all material facts and establishing a live, rational nexus between tangible material and alleged income escapement. General information concerning alleged shell entities, without linking it to the assessee or lender, is insufficient. Unsecured loans supported by account-payee payments, repayment with interest and tax deduction, confirmations, audited accounts, tax returns and bank statements establish creditor identity, creditworthiness and transaction genuineness. On these stated principles, reopening and the related unexplained-loan addition were treated as unsustainable.
Portal-based issuance of reassessment notice determines the applicable procedure and can invalidate jurisdiction for delayed statutory compliance.
Reassessment jurisdiction cannot rest on the date printed on a section 148 notice where portal records show that the notice was made available for communication only later. Issuance occurs when the notice is dispatched or made available for delivery. Where portal issuance occurred on 1 April 2021, the reassessment was governed by the statutory regime then in force, including the prescribed pre-notice procedure. Non-compliance with that procedure and issuance beyond the applicable limitation period invalidated the assumption of reassessment jurisdiction, rendering the consequential assessment proceedings void ab initio.
Unexplained cash deposits during demonetisation warranted a consolidated addition after considering disclosed business income and family savings.
Unexplained cash deposits during demonetisation require a reasonable consolidated assessment where the taxpayer is a small business operator, has disclosed presumptive-taxation turnover, and relies on family savings without separate family bank accounts. Full addition of the deposits, including a post-office investment, was not warranted after considering disclosed turnover, accumulated family savings, and business income already returned. The unexplained-money addition was therefore restricted to a consolidated amount inclusive of disclosed business income, partly favouring the taxpayer.
Sufficient cause for delayed appeal was not established where medical evidence showed no continuing incapacity and business operations continued.
Delay in filing an appeal requires sufficient cause supported by credible evidence explaining the period of default. Medical material did not establish an accident or continuing incapacity after November 2024, and it showed no significant abnormality. The assessee also continued operating a contracting business during the relevant period. No sufficient cause for the delayed filing was established; consequently, the delay was not condoned.
Incriminating material requirement defeats search-assessment additions based on unreliable statements and electronic records lacking credible evidence of undisclosed income.
Search-assessment additions could not be sustained where no credible incriminating material was found against the assessee. The statements and electronic records relied upon arose from the same search material examined in a connected matter and lacked sufficient credibility and reliability to establish undisclosed income or alleged kickbacks. Consistent with the coordinate bench's treatment of the principal searched person, the additions were deleted and the issue was resolved in favour of the assessee.
Assessment after taxpayer's death requires notice to legal representatives; proceedings in the deceased's name are void.
Section 159 requires income-tax proceedings pending at an assessee's death to continue against legal representatives, and proceedings capable of initiation against the deceased to be initiated against them. Post-death assessment therefore requires notice to the legal representatives. An assessment completed in the deceased's name without notice to any legal representative is null and void, as is a consequential demand and a revisional order sustaining it. Portal unavailability during the proposed hearing period further prevented adverse consequences from the legal representative's failure to promptly report the death. Fresh assessment action may proceed only after notice to the legal representatives.
Composite show cause notices spanning multiple tax periods are jurisdictionally invalid, requiring separate period-specific proceedings under Section 74.
A single composite show cause notice under Section 74 cannot validly combine distinct tax periods or financial years. Each tax period must be addressed separately under the statutory scheme; clubbing multiple periods renders the notice jurisdictionally defective. Where adjudication and appellate proceedings are founded on such a composite notice, the defect extends to the consequential orders and proceedings, which are liable to be quashed.
GST
Dated:- 10-8-2026
PTI
Fuel pricing, central excise duty and profits of state-run oil marketing companies are examined through allegations that retail fuel prices and tax policy imposed excessive costs on consumers while generating substantial company profits. The criticism contrasts high crude-price periods with lower retail prices and lower excise duty against a later period in which reduced crude prices were allegedly not passed through to consumers. Profit-margin disclosure is also raised as a transparency issue, with parliamentary information described as covering oil prices, global crude prices and company profits.
PMLA / Black Money
Dated:- 10-8-2026
PTI
Discharge in a money-laundering prosecution was sought before a special PMLA court concerning alleged siphoning and laundering of loans advanced to Jet Airways by Canara Bank. The prosecution was directed to respond, subject to the applicant not seeking adjournment. Discharge is available after filing of a chargesheet and before framing of charges where the material before the court is insufficient to establish the alleged offence. The proceedings arise from a CBI FIR concerning alleged bank fraud involving Jet Airways and associated persons.
Budget
Dated:- 10-8-2026
PTI
Parliamentary oversight calls for accelerated indigenisation of high-speed rail components, capacity-building through international expertise, and comparative study of successful high-speed rail systems for future corridors. Redeveloped stations should be assessed through measurable indicators concerning passenger use, accessibility, cleanliness, commercial occupancy, maintenance and feedback, with completed-project practices documented and shared. Operational cargo terminals and cargo-related facilities should be monitored through a digital dashboard covering utilisation, rake performance, mechanisation, connectivity, safety compliance and customer satisfaction.
Customs & Trade
Dated:- 10-8-2026
PTI
Haryana Progressive MSME and Export Promotion Policy 2026 creates a five-year framework for MSME growth through financial incentives, institutional support, industrial infrastructure, technology adoption and export facilitation. Identified thrust-sector enterprises may receive capital and interest subsidies, stamp duty reimbursement, employment assistance, insurance support, and incentives for automation, artificial intelligence, testing and research. Proposed venture capital and credit guarantee funds seek to improve institutional and collateral-free finance. Export support covers international certifications, credit, insurance, freight, e-commerce, trade fairs, documentation, compliance and buyer connections, alongside sustainability and inclusive entrepreneurship measures.
Income Tax
Dated:- 10-8-2026
PTI
Employee data exposure alerts prompted TCS to review allegations concerning limited basic employee information that appears to be more than four years old. No indication exists that customer data, customer systems, or operational systems have been affected. The alleged vectors involve password spraying and multi-factor authentication fatigue. TCS states that safeguards against these techniques have been in place for more than two years, its controls remain effective, and monitoring and further assessment will continue.
Notification No. 5/2021 Dated:- 11-11-2021 Telangana SGST
Assessment functions for specified taxpayers are assigned to the jurisdictional Additional Commissioner (State Tax) or Joint Commissioner (State Tax) of the relevant division. Assessments must be undertaken exclusively through the Scrutiny Module and in accordance with the prescribed procedure under the Telangana and Central Goods and Services Tax laws.
Customs, DGFT & SEZ
Dated:- 10-8-2026
Mustard honey export from Tripura to Dubai marks the first international shipment by Dergang Farmer Producer Organisation, supported through export-oriented aggregation and market linkage initiatives. The export creates overseas market access for local beekeepers and farmers, diversifies the honey value chain, and encourages quality-focused production. Industry collaboration supported bee production and an export-oriented supply chain, while capacity building, quality assurance, value addition and market linkages can strengthen agricultural exports and farmer participation in international markets.