Residency Rules: Income Tax Act, 1961 vs Income Tax Bill, 2025 — A Subtle Yet Significant Shift!

Residential status is one of the most critical factors in determining an individual’s tax exposure in India. For decades, Section 6 of the Income-tax...

Transfer Pricing and International Tax Reforms under Finance Bill, 2026: A Practical Overview

In an increasingly volatile global economic environment, Budget 2026 reflects India’s conscious shift towards certainty, predictability, and long-term institutional strength in taxation. Rather than...

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CAs Gain Equal Recognition for ITAT Appointments

The Institute of Chartered Accountants of India (ICAI) recently celebrated a landmark judgment by the Supreme Court of India that marks a significant win...

Does Section 115BAA Override Special Tax Rates?

The central issue before the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in Maharishi Education Corporation (P.) Ltd. vs. ITO  was:  Whether a company...

Can a PCIT introduce new issues in a Section 263 order without mentioning them in the Show Cause Notice? 

1. Issue  The central issue before the Income Tax Appellate Tribunal (ITAT), Delhi Bench ‘B’, was whether the Principal Commissioner of Income Tax (PCIT) validly exercised revisionary jurisdiction under Section 263 of...

Can “Diary Notings” and “Retracted Statements” Alone Sustain an Addition? 

In appellate tax practice, the truth is simple: a case is only as strong as the evidence that supports it.  In a recent landmark decision, the Income...

Can Profit Be Taxed Twice on the Same Bogus Purchase? 

When books of accounts are accepted, can the Assessing Officer still tax “profit” on alleged bogus purchases again?  In a recent decision, the ITAT Delhi...

Whether the delay of 304 days in filing the appeal deserved to be condoned in absence of any explanation or affidavit ? 

In the complex world of appellate tax litigation, time isn’t just a procedural formality it’s often the deciding factor between justice and finality.  The Income...

The Aishwarya Rai Bachchan ₹4 Crore Tax Case – Expert Analysis

In 2025, the Income Tax Appellate Tribunal (ITAT), Mumbai Bench, delivered a significant judgment in favor of Ms. Aishwarya Rai Bachchan, setting aside an...

Share sale proceeds not unexplained Karnataka HC upholds ITAT Order deleting Addition of Rs. 7cr. u/s 68.

Facts of the case The assessee filed its return of income, declaring a STCL on sale of shares held in X Ltd. to three entities. The...

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