TMI Short Notes

TMI Short Notes on various issues

101. The Taxation of Cooperative Societies: A Legal Analysis of Deduction Eligibility U/s 80P

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102. Analyzing Section 43B's Application in Service Tax Liabilities: A Legal Perspective.

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103. Assessing the Enforceability of Section 148 Notices Post-Assessee's Demise: Legal Heirs and Income Tax Proceedings

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104. Analyzing the Threshold for Criminal Prosecution in Cases of Non-Compliance with Income Tax Laws

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105. Timeliness and Validity of Charitable Trust Registrations under Section 80G: A Legal Examination

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106. Navigating the Nuances of Income Tax Reassessment Post-Finance Act 2021: Resetting the Clock in Tax Reassessments

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107. The Source Rule in International Taxation: Tax Implications for Non-Resident Service Providers

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108. Taxation of 'Success Fees' in International Transactions: The Nexus Doctrine: Situs of residence and Situs of source of income

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109. TDS and International Transactions: Categorization of Payments under the ambit of "royalty" or "fees for included services (FTS)"

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110. Assessment u/s 153C and Unexplained Investments: A Case Study in Legal Reasoning

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111. Delhi High Court Elucidates on the Scope of Section 80IA in the Context of Business Expansion: Interpretation of 'Undertaking'

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112. Penalty Limitations and Reasonable Cause: Navigating the Nuances of Tax Penalties

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113. Income Tax Return Delays: High Court Rules on Tax Authority's Decision-Making Boundaries

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114. The Interplay of Sales and Bogus Purchases in Tax Evasion Cases: Assessing Tax Evasion Allegations

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115. Proportionality and Evidence in Tax Assessments: Accommodation entries, Bogus Purchase and Estimation of Gross Profit (Income)

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116. Judicial Scrutiny of Tax Deducted at Source (TDS) Non-Deposit: Protecting the Rights of Taxpayers Against Employers' Failure to Deposit TDS

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117. Dynamics of Tax Exemption Registrations: A Comprehensive Analysis of ITAT Ahmedabad’s Decision on Section 80G Application Rejection

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118. Transfer Pricing Litigation: The Evolving Landscape of Arm's Length Price Determination in India

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119. Revisiting the Scope of Revisionary Powers U/s 263: Assessing the Adequacy of Assessment Procedures in Taxation Disputes

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120. Maintaining the Sanctity of Search and Seizure Procedures: Emphasizing the rigorous compliance with procedural requirements to uphold the legitimacy of search and seizure operations

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121. Analyzing the Tax Implications of Cross-Border Payments: Recognizing the payments as either 'Royalty' or 'Fee for Included Services' u/s 9(1)(vii)

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122. Non-Delegability of Discretionary Powers in Income Tax Assessments: Administrative Discretion in Special Tax Audit Procedures u/s 142

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123. Taxation of Domain Registration Services in Godaddy.Com LLC Case: Tax Implications for Digital Services

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124. Navigating the Complexities of Section 80P Deductions for Cooperative Societies

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125. Navigating Pecuniary Jurisdiction in Tax Assessments: Assessment Orders and Legal Jurisdiction

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126. "Sales Tax Subsidy and Its Classification in Income Tax: Revenue or Capital receipt

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127. Trust Registration and Tax Exemptions in India: rejection of registration u/s 12AB for want of supporting evidences

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128. Condonation of Delay in Taxation in filing applications for registration u/s 12A/12AA:

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129. Navigating Procedural Timelines in Tax Exemption Applications

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130. Mandatory Draft Assessment Orders for Foreign Entities and Section 144C Compliance: A Legal Perspective

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131. The Impact of PAN Mismatch in Corporate Tax Filings and Resolving Name Discrepancies in Tax Documents: Legal Implications and Remedies

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132. Analyzing the Dispute Over Section 14A Disallowance and Interest under Section 244A in Income Tax Appeals

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133. Condonation of Delay in Tax Refund: Analyzing the Right to Interest

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134. Balancing Corporate Operations and Tax Obligations: High Court's Interim Order on Share Buyback Taxation

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135. Section 80P and Cooperative Societies: Unraveling the Tribunal's Interpretation

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136. Supreme Court Upholds High Court's Decision on Tax Evasion Case: An Analysis

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137. Reassessing Accommodation Entries: Insights from a High Court Judgment

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138. A Judicial Perspective on Section 148A of the Income Tax Act: Amended Reassessment Provisions

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139. Threshold set for monetary limits in filing appeals by Revenue: A policy shift towards reducing litigation and financial burden on the judiciary and taxpayers

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140. High Court's Stance on Penalty Notices in Tax Law: A Balance Between Procedure and Justice

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141. Decoding the Penalty Provisions under Section 271(1)(c): Analyzing the Fine Line Between Concealment and Inaccuracy in Taxation

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142. Levy of penalty under Section 271(1)(c) of the Income Tax Act: Between Legal Intent and Factual Circumstances

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143. Assessing Penalties for non-filing of ITR: A Deep Dive into Section 271F of the Income Tax Act

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144. Addition after survey option as Unaccounted income: Burden to prove and evidence.

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145. Decision on Depreciation and Expenditure

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146. Navigating Through Reimbursement Expenses, DDT Refunds, and Transfer Pricing Adjustments

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147. Navigating Financial Distress: A Legal Analysis of Progressive Tax Instalment Judgments

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148. Deciphering Tax Implications on Capital Reduction: Navigating the Complexities of Section 115QA in ITAT's Decision on Capital Reduction Transactions

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149. Interpreting Section 153A: ITAT Delhi's Stand on Incriminating Material in Assessments: Assessments following search and seizure operation.

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150. Reaffirming the Bounds of Section 153A: Analysis of Delhi High Court's Approach: Assessment post search and seizure

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