TMI Short Notes

TMI Short Notes on various issues

1. Judicial Recall and Tax Implications in Trust Settlements: Using AI-generated citations without proper verification

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2. Corporate Mergers and Tax Assessment: Navigating Legal Entity Changes and rectification u/s 292B

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3. Reconciling Procedural Timelines with Limitation Periods in Income Tax Reassessments

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4. Condoning Delay in Filing Income Tax Return: A Case for Equitable Consideration

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5. Disallowance u/s 14A: Navigating the Interplay of Exempt Income and Expenditure

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6. Taxation of International Consulting Services: Navigating the Complexities

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7. Examining the Eligibility of Credit Co-operative Societies for Deduction on Interest from Co-operative Bank Deposits

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8. Draft Assessment Order Regime: Navigating the Multi-tiered Assessment Process and Distinct Nature of Section 144C Assessments

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9. Judicial Scrutiny of Section 14A Amendment: Retrospective or Prospective Effect?

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10. Tax on Royalties: Navigating the Interplay between Domestic Tax Laws and Double Taxation Avoidance Agreements

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11. Validity of Assessment u/s 153C: Reckoning the Limitation Period

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12. Interpreting 'Initiation' of Penalty Action u/s 275(1)(c): Period of Limitation

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13. Faceless Assessment: Decoding the Exemptions for International Tax Charges

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14. Decoding the Interplay of Sections 153A and 153C in Search Assessments: Limitation and Reassessment Dynamics

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15. Income Tax Case Transfers: Place of Business vs. Registered Office: Determining the Appropriate Jurisdiction for Income Tax Assessments

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16. Validity of Writ Petitions and Section 153C Proceedings: Examining the High Court Judgment

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17. Interpreting Time Limits for 80G Registration for Charitable Institutions: Avoiding Absurdity in the Law

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18. Interplay between the provisions of Section 153C and Section 147: Limits on Automatic Reassessment in Search Cases

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19. Equity and Justice in Tax Matters: Condonation of Bona Fide Delays

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20. Embracing Equity in Tax Laws: Recognizing Genuine Difficulties in Condonation of Delays in filing of ITR

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21. Real Income Taxation: Avoiding Double Disallowance of Wages and Salaries Payable

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22. Jurisdictional Prerequisites for Initiating Reassessment u/s 148: Non-Depoist of TDS by the Employer

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23. Revisiting the Scope of "Record" u/s 263: Embracing Subsequent Records

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24. Interpreting "Record": Revisiting the Scope of Revision Powers u/s 264 and Rectification of Mistake u/s 154

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25. Supreme Court Upholds Validity of Re-Assessment Notices Issued During COVID-19 Lockdown

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26. Navigating the Faceless Assessment Regime: A Judicial Perspective

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27. Evidentiary Value of Statements Recorded During Income Tax Surveys: A Judicial Analysis

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28. Faceless Assessment: Ensuring Compliance with Statutory Provisions

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29. Faceless Assessment Mechanism: Jurisdictional Limits in Income Tax Proceedings

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30. Reassessment Notices for AY 2013-14: Upholding the Doctrine of Limitation

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31. Decoding the Mandatory Timelines: A Thorough Examination of the Income Tax Assessment Order Nullification

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32. Stay of Tax Demand: Interpreting the Discretionary Power u/s 220(6) of the Income Tax Act

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33. Interpreting "Technical Services" under Tax Treaties: A Comprehensive Analysis

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34. Navigating the Registration Process u/s 80G: Insights from the ITAT Ruling

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35. Ensuring Fair Proceedings: The Importance of Proper Notice Service in Income Tax Matters

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36. Unraveling the Royalty Conundrum and DTAA: ITAT's Stance on Marketing and Reservation Fees

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37. Royalty or Not? Decoding the Taxability of Marketing and Reservation Contributions under India-USA DTAA

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38. Unraveling the Intricacies: Assessing a Political Party's Claim for Income Tax Exemption

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39. Bogus Capital Gains and Accommodation Entries: Unraveling the Penny Stock Scam and Tax Evasion

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40. Strict Interpretation of Exemption Provisions: Supreme Court's Ruling on Section 10B(8) of the Income Tax Act

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41. Disallowance u/s 14A: Prospective or Retrospective Effect of the Amendment?

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42. Navigating the Complexities of "Charitable Purpose" in Income Tax Exemptions

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43. Cooperative Banks vs. Primary Agricultural Credit Societies: Implications for Section 80P Deduction

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44. Exemption u/s 11: Condonation of Delay in Filing Form 10

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45. Interpreting Section 249(4)(b) of the Income Tax Act: When Non-Payment of Advance Tax Cannot Dismiss an Appeal

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46. Retrospective Amendments and the Doctrine of Vested Rights: A Judicial Perspective

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47. Upholding Equality: HC Strikes Down Discriminatory Circular on Charitable Trust Approvals

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48. Judicial Review of Income Tax Settlement Commission (ITSC) Orders: Navigating the Boundaries

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49. Assessee's Lackadaisical Conduct Leads to Dismissal of Income Tax Appeal

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50. Navigating the Faceless Appeal Scheme: Lessons from the Judgement on Delayed Filing and Deduction u/s 36(1)(va)

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