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Corporate Guarantees under GST: Insights from the Bombay High Court's Split Decision
Background and Issue OverviewThe recent amendments to Rule 28 of the Central Goods and Services Tax (CGST) Rules, 2017, particularly regarding corporate guarantees, have generated significant debate a...
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Automated GST Interest Notices for FY 2019–20: Can Section 50 Override Statutory Limitation?
OverviewAssessees across India have recently begun to receive automated alerts labeled as “Notice for Delayed Reporting of Outward Supplies,” demanding payment of interest under Section 50 of the Cent...
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NRI Tax Compliance: Insights from Mumbai Tribunal’s Order—A Cautionary Tale
Overview: Relevance of Mumbai Tribunal’s Order for NRIsThe Mumbai Tribunal’s verdict in Sonepal Singh Kohli v. Income-tax Officer (Int-Tax) [2026] 187 taxmann.com 326 (Mumbai - Trib.) serves as a crit...
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Analysis of Unexplained Cash under the Benami Act: Insights from Yoosaf N A v. Initiating Officer (BPU)
OverviewOn 14 May 2026, the Appellate Tribunal under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 (SAFEMA), New Delhi, delivered its decision in the matter of Yoo...
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Supreme Court Non-Interference in GST Matters: What Really Survives After Dismissal of an SLP?
1. The larger point: every dismissal by the Supreme Court does not mean the same thingGST law in India is developing not only through detailed Supreme Court judgments but also through cases where the...
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GST Treatment of Cross-Border Procurement Support: What the Dow Chemical GSTAT Decision Means for Multinationals
1. Why the Dow Chemical ruling mattersThe GST Appellate Tribunal’s decision in the case involving Dow Chemical International Private Limited, India and services received from Dow Europe GmbH, Switzerl...
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GST on Transfer of Leasehold Rights: Why Aerocom Helps, but Final Certainty Still Awaits
The GST treatment of assignment of leasehold rights in industrial plots continues to be one of the most debated issues for businesses operating from land allotted by State Industrial Development Corpo...
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Search Assessments After 1 April 2021: Why Section 143(3) Cannot Replace the Statutory Route Under Sections 147, 148 and 148B
1. From the old search code to the new reassessment frameworkBefore 1 April 2021, assessments following a search were governed by a distinct mechanism contained in Sections 153A to 153D of the Income-...
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Section 271DA Penalty Requires Proof, Not Presumption: Lessons from the Hyderabad ITAT Ruling in the Vasavi Group Cases
The Hyderabad Bench of the Income Tax Appellate Tribunal, by its order dated 24 June 2026, decided a batch of 42 appeals concerning the Vasavi Group. The ruling is important because it examines the pr...
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Penalty on Estimated Income: Why the Old Protection Is Now Narrower
For many years, taxpayers relied on a familiar proposition under the Income-tax Act, 1961: if an addition was made merely by estimation, penalty for concealment or furnishing inaccurate particulars wa...
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Income-tax Consequences of Loans, Credits, Share Capital and Unexplained Receipts under Section 68
1. Statutory setting: why unexplained credits are treated seriouslySection 68 of the Income-tax Act, 1961, corresponding broadly to section 102 of the Income-tax Act, 2025, is the central provision de...
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Supreme Court’s Initiative on AI Integration in Judiciary
1. Introduction: Supreme Court’s Initiative on AI Integration in JudiciaryThe Supreme Court of India has recently unveiled a draft regulation governing the deployment of Artificial Intelligence (AI) i...
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Tax Treatment of Lump-Sum Amounts Paid by Employers to Employees
As the income-tax return filing cycle for salaried individuals gains momentum and employers prepare quarterly tax compliance data for Financial Year 2025–26, one area that requires particular attentio...
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Section 54F and Section 54B: Why the Name on the Purchase Deed Can Change the Tax Result
Relief provisions dealing with reinvestment of capital gains are intended to encourage taxpayers to convert one capital asset into another specified asset. However, a difficult question repeatedly ari...
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Why Rotation of Directors Has Lost Its Governance Value for Listed Companies
1. The central pointThe rule on retirement of directors by rotation in Section 152(6) and Section 152(7) of the Companies Act, 2013 continues to operate in Indian company law, but its usefulness for l...
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GST Treatment of Free Samples: Taxability, ITC Reversal and Practical Safeguards
Free samples are a common business tool, particularly in pharmaceuticals, FMCG, medical devices, cosmetics and technology products. Businesses distribute them to create market awareness, encourage pro...
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Income-tax Act, 2025: Transitional Errors May Invalidate Post-2026 Actions for Pre-2026 Years
The shift from the Income-tax Act, 1961 to the Income-tax Act, 2025 is not merely a change of numbering or drafting style. The repeal-and-savings provision in the new law creates a strict dividing lin...
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Tax Treatment of Legal Representatives, Representative Assessees, Trusts, AOPs and BOIs under Sections 302 to 311 of the Income Tax Act, 2025
Sections 302 to 311 of the Income Tax Act, 2025 create a connected code for assessment and recovery where income is received or managed by someone other than the beneficial owner, or where income aris...
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Section 148 Notices Prior to 1 April 2022: Why Separate Approval Was a Mandatory Jurisdictional Requirement
The reassessment regime under the Income-tax Act, 1961 has always involved a delicate balance. On one hand, the Revenue must have the power to bring escaped income to tax. On the other hand, reopening...
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When Regulatory Levies Become Taxable: Analyzing the Tax Implications of Landmark Non-Tax Judgments
Regulatory Payments and Their Tax Afterlife: Lessons from OTSC and Mineral Royalty LitigationA dispute may begin as a challenge to a government demand, a licence condition, a mineral levy or a regulat...