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Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025
Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025Section 170 of the Income Tax Act, 2025 provides that a secondary adjustment shall be made in c...
Principle of Peak Credit Theory under Income Tax Act, 1961 – Complete Analysis with Landmark Case Laws, Section 68 & Judicial Findings
Principle of the Peak Credit Theory in Income TaxMeaning of Peak credit theory :§ Instead of taxing entire deposits, only the maximum unexplained balance (peak) is taxed§ Because wi...
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...
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...
Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015
Black Money (Undisclosed Foreign
Income and Assets) and Imposition of Tax Act, 2015 Sections 44 and 45Penalty Provisions – Statutory
Exclusions, Monetary Thresholds and ESOP Amendment 1. Overview:-The Black...