Overseas Commission to Non-Resident Agents Not Disallowable u/s 37(1): Ahmedabad ITAT in DCIT v. Kewalram Textiles Pvt. Ltd. (AY 2017-18) Relying on CIT v. Toshoku Ltd.

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CA. Ajay Kumar agarwal
24/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 538
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Whether commission paid by an export-oriented assessee to non-resident agents, for services rendered outside India, can be disallowed under section 37(1) of the Income-tax Act, 1961 on the ground of alleged lack of ge...

GAAR Not Applicable Without ‘Impermissible Avoidance Arrangement’: Telangana High Court Quashes GAAR Proceedings on Share Transactions | Smt. Anvida Bandi v. DCIT [2025] 177 taxmann.com 726 (Telangana HC)

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My Tax Expert
20/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 591
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In recent judgement (September, 2025) Telangana High Court quashes GAAR proceedings in absence of an ‘impermissible avoidance arrangement’(IAA)In Smt. Anvida Bandi v Deputy Commissioner of Income Tax, [2025] 177 taxm...

Bogus Political Donations Returned After Commission: Delhi ITAT Denies Section 13A Exemption, Taxes 6% as Income u/s 56(1) | Public Political Party v. DCIT (ITAT Delhi, 2025)

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My Tax Expert
20/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 1134
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Denies benefit under section 13A to political party as bogus donation returned to donors after deducting commission Delhi ITAT partly allows Assessee’s appeal observing that the addition under section 68 cannot be sus...

Rate of Exchange for Conversion into Rupees of Income Expressed in Foreign Currency, (Rule 115 of the Income-tax Rules, 1962)

Author
CA. Ajay Kumar agarwal
17/12/2025  |  1 COMMENTS  |  VISITOR'S COUNT: 3144
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Rate of Exchange for Conversion into Rupees of Income Expressed in Foreign Currency (Rule 115 of the Income-tax Rules, 1962) Foreign income and capital gains are becoming increasingly common as Indian residents invest ...

Disclosed Foreign Investments in Minors’ Names Not Unexplained u/s 69; Foreign Tax Credit Cannot Be Denied for Procedural Lapse in Form 67 – ITAT Delhi

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CA. Ajay Kumar agarwal
17/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 737
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Core Issue:-The principal controversy before the Delhi Bench of the Income Tax Appellate Tribunal was whether investments made in foreign shares in the names of the assessee’s minor daughters could be treated as une...

“Reasonable Cause” and “Sufficient Cause” under the Income-tax Act, 1961 – Conceptual Distinction, Statutory Application and Judicial Approach

Author
CA. Ajay Kumar agarwal
17/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 1072
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“Reasonable Cause” and “Sufficient Cause” under the Income-tax Act, 1961 – Conceptual Distinction, Statutory Application and Judicial ApproachIntroductionThe Income-tax Act, 1961, while prescribing strict ti...

Taxability of Ex-gratia / Retrenchment Compensation Paid Under Government-Supported Schemes – Statutory Framework, Judicial Interpretation and Admissibility of New Claim

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CA. Ajay Kumar agarwal
17/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 2066
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Taxability of Ex-gratia / Retrenchment Compensation Paid Under Government-Supported Schemes – Statutory Framework, Judicial Interpretation and Admissibility of New ClaimThe taxability of ex-gratia compensation paid...

Penalty proceedings u/s 274 r/w section 271(1)(c) - estimation of income - bogus purchases

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CA. Ajay Kumar agarwal
16/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 790
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Penalty proceedings u/s 274 r/w section 271(1)(c) - estimation of income - bogus purchases  ITAT MUMBAI:-Amish Anantrai Modi Versus Deputy Commissioner of Incometax, Central Circle 2 (1), Mumbai,No.- I. T. A No....

Delhi High Court Upholds PCIT-Only Sanction for High-Value Tax Evasion Prosecution: Collegium Approval Not Required Under CBDT Circulars

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CA. Ajay Kumar agarwal
12/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 629
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Saumya Chaurasia v. Union of India & OthersDelhi High Court | WP(C) 8191/2025 | Dec 8, 2025** 1. Core Issue:-Whether, for prosecution under Section 276C(1) (wilful attempt to evade tax) and Section 278E (pre...

Whether the assessment framed u/s 153A for Assessment Year 2010-11 (pursuant to search action) was barred by limitation, as it fell beyond the permissible extended period of 10 years prescribed under Explanation 1 to Section 153A(1), particularly in light of the binding judgment of the Delhi High Court in Ojjus Medicare Pvt. Ltd

Author
CA. Ajay Kumar agarwal
11/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 488
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Whether the assessment framed u/s 153A for Assessment Year 2010-11 (pursuant to search action) was barred by limitation, as it fell beyond the permissible extended period of 10 years prescribed under Explanation 1 to ...