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How to Respond to Penalty Levied under Section 271(1)(c) of the Income Tax Act, 1961
How to Respond to Penalty Levied under Section 271(1)(c) of the
Income Tax Act, 1961IntroductionSection 271(1)(c) of the Income Tax Act, 1961 provides for the
imposition of penalty where an assessee has concealed the p...
Section 153C Notices Quashed Without AY-Specific Incriminating Material — Delhi High Court in Ashutosh Agarwal vs ACIT (Central Circle-28), WP(C) 992/2024 & Connected Matters (09 April 2024)
Facts of the CaseA batch of writ petitions challenged notices issued under
Section 153C of the Income Tax Act, 1961 to assessees who were not subjected to
the original search. The petitioners contended that no incrimin...
Presumptive Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse, and International Comparisons
Presumptive
Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse,
and International ComparisonsAbstract
This article examines presumptive taxation under the Income‑tax Act, 2025. It
is...
Ex-Parte and Non-Speaking Appellate Order Violative of Section 250(6): ITAT Allahabad Sets Aside CIT(A) Order Passed Under Faceless Regime – Ram Lakhan Maurya vs Assessment Unit (AY 2015-16)
Facts of the CaseThe assessee, an individual, filed his
return of income for Assessment Year 2015-16 declaring total income of
₹2,41,890. The Assessing Officer completed the assessment under section 147
read with se...
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?The sumptuary allowance is a specific benefit provided to judicial officers in India to cover entertainment expenses. This allo...
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA): Determination of Tax Residence in Dual Residency Cases with Key Judicial Precedents
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)The Tie breaker rule for residential status refers to the criteria used to determine an individual’s primary place of residence, usually for tax purpos...
Appeal Maintainable Despite Low Tax Effect Due to Accommodation Entry Exception: Delhi High Court in Pr. CIT-1 v. Agroha Fincap Ltd. (ITA No. 60/2024, 23.12.2025)
Delhi High Court:-Pr. Commissioner
of Income Tax – 1 VersusM/s Agroha Fincap Ltd.ITA No. 60/2024 | Judgment dated: 23 December 2025 CORE ISSUE:-Whether the appeal
filed by the Revenue before the High Court was m...
ITR-U Under Section 139(8A): A Costly Last Resort After 31st December for Missed Belated and Revised Returns
ITR-U: The High-Cost Compliance Window Beyond 31st DecemberA taxpayer who misses the 31st December deadline for filing a belated or revised return exits the normal compliance cycle. The only remaining recourse thereafter...
Supreme Court on Section 44C: DIT (Intl. Tax), Mumbai v. American Express Bank Ltd. – Cap on Head Office Expenditure for Non-Residents Reaffirmed (Judgment dated 15.12.2025)
Analysis of judgement of Supreme Court delivered on 15.12.2025 in the case of Director of Income Tax, Mumbai v. M/s American Express Bank Ltd., on the issue of Deduction of head office expenditure in the case of non-resi...
Schedule FA Disclosure in ITR Explained: Foreign Assets, ESOPs, RSUs, Dividends & Penalties under Black Money Act | Complete Compliance Guide
Schedule FA
(Foreign Assets) is mandatory for Resident & Ordinarily Resident
(ROR) individuals who hold any foreign asset or foreign income at
any time during the relevant financial year, even if:
Asset is d...