Tribunal denies Section 80G recognition to hospital trust for commercial outsourcing model generating substantial surplus with minimal charitable application

  ITAT Ranchi Decision on Section 80G Recognition :- Jeevan Rekha Trust v. CIT (Exemption), Patna- ITA Nos. 23 & 24/RAN/2025 | Order dated 05 January 2026- Assessment Years: 2023–24 & 2024–25 CORE ISSUE: Whether a trust earning income by outsourcing its hospital building to a private entity and receiving consideration as a percentage of … Read more

Subsequent proceeding after – DTDRS certificate granting immunity had been issued

No Vivad After Vivad: Finality of Amnesty Immunity and Limits of Revisional Power under the Income-tax Act Rajasthan High Court reaffirms closure under DTDRS 2016 – Penalty cannot be resurrected via Section 263 Principal Commissioner of Income Tax–I, Jaipur v. Shri Ram Das Maheshwari D.B. Income Tax Appeal No. 336 of 2018 Decision dated 11 … Read more

Stay of Income-tax demand – whether 20% of disputed tax is mandatory

  Stay of Demand and the 20% Recovery Rule: Statutory Framework, CBDT Instructions and Judicial Reinforcement by the Bombay High Court The power of the Income-tax Department to recover tax demand during the pendency of appellate proceedings is statutorily traceable to section 220 of the Income-tax Act, 1961, which provides that any amount specified as … Read more

Benami Transactions, Demonetisation Cash Routing and Provisional Attachment

Benami Transactions, Demonetisation Cash Routing and Provisional Attachment Statutory Definitions, “Reasons to Believe” under Section 24(1), and the Doctrine of Independent Satisfaction M/s Bajrang Traders v. Initiating Officer, BPU, Ahmedabad Decision: 10 December 2025 (Appellate Tribunal under SAFEMA) The decision rendered by the Appellate Tribunal under SAFEMA, New Delhi, in M/s Bajrang Traders v. Initiating … Read more

Revision under section 264 vs Appeal under section 246A – Scope of Discretion, Errors in Return and Preventive Role of Revisional Jurisdiction

Revision under Section 264 vis-Ă -vis Appeal under Section 246A: Scope of Discretion, Errors in Return and the Preventive Role of Revisional Jurisdiction – An Analysis of the Bombay High Court decision in Swaminarayan Mandir Trust The recent decision of the Bombay High Court in Swaminarayan Mandir Trust Versus Commissioner of Income Tax (Exemptions), Mumbai & … Read more

Addition under Section 69 of Income Tax Act 1961- On Money – purchase of Shop

  ITAT Mumbai Strikes Down Additions for Want of Proof Ajay Kumar Agrawal Nehru Place, New Delhi (For Professional Circulation) 03 January 2026 The decision of the Mumbai Bench of the Income Tax Appellate Tribunal, Mumbai Bench in Jayantilal Purohit v. Deputy Commissioner of Income Tax, Central Circle–4(2), Mumbai (ITA Nos. 5682, 5683 and 5684/Mum/2025, … Read more

TDS u/s 195 on Sponsorship & Trademark Rights – Indo-Singapore DTAA

  CA AJAY KUMAR AGRAWAL Nehru Place, New Delhi Case Reference – 0004 | Date: 31/12/2025 For Professional Circulation Delhi High Court | Judgment dated 24 December 2025 W.P.(C) 15181/2004 LG Electronics India Pvt. Ltd. & Anr. Versus Director of Income Tax (International Taxation) & Anr. Core Issue: The core issue before the Delhi High … Read more

Condonation of Delay for Filing Return of Income u/s 119(2)(b)

Delhi High Court | Judgment dated 23 December 2025 W.P.(C) 19589/2025 & CM Appl. 81894/2025 Manjit Singh Dhaliwal versus Commissioner of Income Tax (International Taxation)-01, New Delhi The Delhi High Court examined the scope and limits of the power of condonation of delay under section 119(2)(b) of the Income-tax Act, 1961, in the context of … Read more

Penalty for cash transactions in property

  Shri Jagdish Prashad Gupta Vs  Joint Commissioner of Income Tax, Range – 1(1), Muzaffarnagar ITA No. 3822/Del/2024 | ITAT Delhi Assessment Year: 2017-18 Order dated: 23 December 2025   CORE ISSUE: Whether penalty under section 271D of the Income-tax Act, 1961 for alleged violation of section 269SS can be sustained in a case where … Read more