Whether interest expenditure incurred on borrowed funds can be allowed as a deduction under section 57(iii) against interest income earned from loans and advances given to a company, when the intention and nexus between borrowing and lending are established. Citation: Ankur Chandulal Shah vs Assistant Commissioner of Income Tax, Circle-19(1), Mumbai ITA No. 5901/Mum/2025-Assessment Year: … Read more
Depreciation on Goodwill arising on Slump Sale of Going Concern Core Issue: Whether goodwill arising from the acquisition of a manufacturing unit as a going concern through a slump sale being the excess of the consideration paid over the net assets acquired constitutes an intangible asset eligible for depreciation under section 32(1)(ii) of the Income-tax … Read more
Introduction The Delhi High Court in the case of ARM Digital Media Pvt.Ltd. V. Ritesh Singh (2025), decided by Justice Purushaindra Kumar Kaurav, looked into whether issues from employment agreements fall under the definition of “commercial disputes” as per the Commercial Courts Act, 2015. The Court concluded that employment contracts are personal service agreements and not commercial disputes. … Read more
Revision u/s 264 – PCIT bound to follow ITAT Special Bench: Tax on Deemed STCG u/s 50 at LTCG rate u/s 112 Bombay High Court-Samir N. Bhojwani. vs. Principal Commissioner of Income Tax & Ors. Writ Petition (L) No. 37709 of 2025 Decision dated: 06 January 2026 Core Issue: Whether, while exercising revisionary jurisdiction under … Read more
Invalid Reopening of Assessment Based on Share Valuation Derived Solely from Share Premium in Third-Party Transaction An Integrated Analysis with Statutory Framework and Finality by the Supreme Court I. Introduction The controversy surrounding reopening of completed assessments on the issue of share valuation has been a recurring theme in income-tax litigation, particularly where the … Read more
Taxability of Consultancy Income under India–UAE DTAA vis-à-vis Significant Economic Presence (SEP) Vijay Mariappan Austin Prakash v. ACIT International Taxation Income Tax Office Visakhapatnam ITAT Visakhapatnam – ITA No. 89/VIZ/2025 | Order dated: 05 December 2025 I. Core Issue Whether consultancy services rendered by a UAE tax resident to an Indian company fall within … Read more
The Impact of India’s New Income-Tax Act, 2025: Simplification, Compliance & Taxpayer Relief The Income Tax Act, 2025, effective from 1-4-26, marks a transformative step towards a more equitable and efficient tax system in India, benefiting taxpayers, businesses, and the economy at large. For Income tax Practitioners, understanding these nuances is essential to empower … Read more
ITAT Delhi – Goswami Bhagwan Lal Education Society v. Income Tax Officer Exemption Ward Faridabad ITA No. 2238/Del/2025 | Order dated: 27 November 2025 Coram: Shri Challa Nagendra Prasad (JM) & Shri Avdhesh Kumar Mishra (AM) Core Issues 1. Whether denial of alternate exemption under section 11 of the Income-tax Act, 1961 at the stage … Read more
Reassessment for A.Y. 2015–16 After 1 April 2021 Held Void – Bombay High Court Reaffirms Binding Nature of Revenue’s Concession The Bombay High Court, in Selvakumar Vethamonickam Nadar v. Income Tax Officer Ward 34(3)(2), Mumbai (Writ Petition (L) No. 41554 of 2025, decided on 24 December 2025), has once again conclusively settled the law governing reassessment proceedings for Assessment Year … Read more
GST Exemption Clarified: Individual vs. Group Health Insurance. The Kerala High Court recently ruled that the Goods and Services Tax (GST) exemption under Notification No. 16/2025-CT(Rate) is applicable only to individual health insurance policies, and not to group health insurance policies, even for retired bank employees. This judgement and the limited exemption on individual … Read more
