TMI Short Notes

TMI Short Notes on various issues

41. Penalty Limitations and Reasonable Cause: Navigating the Nuances of Tax Penalties

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42. Income Tax Return Delays: High Court Rules on Tax Authority's Decision-Making Boundaries

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43. The Interplay of Sales and Bogus Purchases in Tax Evasion Cases: Assessing Tax Evasion Allegations

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44. Proportionality and Evidence in Tax Assessments: Accommodation entries, Bogus Purchase and Estimation of Gross Profit (Income)

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45. Judicial Scrutiny of Tax Deducted at Source (TDS) Non-Deposit: Protecting the Rights of Taxpayers Against Employers' Failure to Deposit TDS

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46. Dynamics of Tax Exemption Registrations: A Comprehensive Analysis of ITAT Ahmedabad’s Decision on Section 80G Application Rejection

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47. Transfer Pricing Litigation: The Evolving Landscape of Arm's Length Price Determination in India

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48. Revisiting the Scope of Revisionary Powers U/s 263: Assessing the Adequacy of Assessment Procedures in Taxation Disputes

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49. Maintaining the Sanctity of Search and Seizure Procedures: Emphasizing the rigorous compliance with procedural requirements to uphold the legitimacy of search and seizure operations

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50. Analyzing the Tax Implications of Cross-Border Payments: Recognizing the payments as either 'Royalty' or 'Fee for Included Services' u/s 9(1)(vii)

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51. Non-Delegability of Discretionary Powers in Income Tax Assessments: Administrative Discretion in Special Tax Audit Procedures u/s 142

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52. Taxation of Domain Registration Services in Godaddy.Com LLC Case: Tax Implications for Digital Services

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53. Navigating the Complexities of Section 80P Deductions for Cooperative Societies

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54. Navigating Pecuniary Jurisdiction in Tax Assessments: Assessment Orders and Legal Jurisdiction

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55. "Sales Tax Subsidy and Its Classification in Income Tax: Revenue or Capital receipt

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56. Trust Registration and Tax Exemptions in India: rejection of registration u/s 12AB for want of supporting evidences

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57. Condonation of Delay in Taxation in filing applications for registration u/s 12A/12AA:

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58. Navigating Procedural Timelines in Tax Exemption Applications

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59. Mandatory Draft Assessment Orders for Foreign Entities and Section 144C Compliance: A Legal Perspective

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60. The Impact of PAN Mismatch in Corporate Tax Filings and Resolving Name Discrepancies in Tax Documents: Legal Implications and Remedies

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61. Analyzing the Dispute Over Section 14A Disallowance and Interest under Section 244A in Income Tax Appeals

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62. Condonation of Delay in Tax Refund: Analyzing the Right to Interest

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63. Balancing Corporate Operations and Tax Obligations: High Court's Interim Order on Share Buyback Taxation

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64. Section 80P and Cooperative Societies: Unraveling the Tribunal's Interpretation

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65. Supreme Court Upholds High Court's Decision on Tax Evasion Case: An Analysis

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66. Reassessing Accommodation Entries: Insights from a High Court Judgment

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67. A Judicial Perspective on Section 148A of the Income Tax Act: Amended Reassessment Provisions

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68. Threshold set for monetary limits in filing appeals by Revenue: A policy shift towards reducing litigation and financial burden on the judiciary and taxpayers

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69. High Court's Stance on Penalty Notices in Tax Law: A Balance Between Procedure and Justice

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70. Decoding the Penalty Provisions under Section 271(1)(c): Analyzing the Fine Line Between Concealment and Inaccuracy in Taxation

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71. Levy of penalty under Section 271(1)(c) of the Income Tax Act: Between Legal Intent and Factual Circumstances

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72. Assessing Penalties for non-filing of ITR: A Deep Dive into Section 271F of the Income Tax Act

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73. Addition after survey option as Unaccounted income: Burden to prove and evidence.

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74. Decision on Depreciation and Expenditure

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75. Navigating Through Reimbursement Expenses, DDT Refunds, and Transfer Pricing Adjustments

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76. Navigating Financial Distress: A Legal Analysis of Progressive Tax Instalment Judgments

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77. Deciphering Tax Implications on Capital Reduction: Navigating the Complexities of Section 115QA in ITAT's Decision on Capital Reduction Transactions

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78. Interpreting Section 153A: ITAT Delhi's Stand on Incriminating Material in Assessments: Assessments following search and seizure operation.

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79. Reaffirming the Bounds of Section 153A: Analysis of Delhi High Court's Approach: Assessment post search and seizure

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80. Navigating Rectification and Revised Returns: Legal Insights from ITAT Bangalore's Ruling

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81. Mutual Fund Gains and Deemed Dividends: Analyzing the Delhi High Court's Landmark Judgment

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82. Reassessing Income under Section 147 Post-Quashment of Sections 153A/153C: The Waiver of Limitation under Section 150(2)

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83. Section 153A of the Income Tax Act: A Critical Analysis of the Supreme Court's Interpretation in the Context of Search and Seizure

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84. Clarity and Precision in Tax Penalty Proceedings: Insights from a High Court Judgment

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85. Jurisdictional Challenges in Tax Assessments: Insights from a Recent ITAT Decision

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86. High Court Rules on the Invalidity of Reassessment Notices Issued to a Deceased Person

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87. Long-Term Capital Gains and Unexplained Cash Credits in Stock Transactions: A Legal Perspective

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88. Judicial Approach in Transfer Pricing and PE Attribution: Analysis of a Landmark Case: Legal Perspectives from Tribunal to Supreme Court

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89. Scrutinizing the Application of Mind in Tax Assessments: Examining the Role of ACIT while granting approval u/s 153D

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90. TDS Obligations and DTAA: Clarifying Tax Jurisdiction in International Telecom Services

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