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India’s New Tax Valuation Framework: How the Income-tax Act, 2025 Recasts the Role of Valuers
The Income-tax Act, 2025 does more than simplify and reorganise India’s direct tax law. One of its most important institutional changes is the creation of a separate statutory framework for valuation...
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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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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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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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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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Exploring the Depths of Section 54: Preservation of Long-Term Capital Gain Character Even on Early Sale of New Asset
Overview1.1 Introduction to Section 54 and Its Judicial InterpretationThe essence of long-term capital gains (LTCG) realized from the transfer of a residential property, as covered by section 54 of th...
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Section 195 and Its Timing: Does Taxation Precede Assessment?
Introduction to Section 195 and Related ProvisionsSection 195 of the Income-tax Act, 2025 prescribes a flat tax rate of 60% on specific sums covered under Sections 102 to 106, which correspond to Sect...
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Taxation of Whistleblower Rewards: Capital Receipt, Windfall, or Taxable Income?
1. Introduction to Whistleblower Rewards and Tax Implicationsi) Background and ContextThe question of whether rewards received by whistleblowers, particularly those who expose tax evasion or corporate...
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Overhauled Framework for TDS and TCS Under the Income Tax Act, 2025: Key Changes, Structure, and Practical Guide
Overview: Major Transformation in TDS and TCS ComplianceThe introduction of the Income Tax Act, 2025, marks a fundamental shift in how tax deducted at source (TDS) and tax collected at source (TCS) ar...
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Section 151 and the Jurisdictional Challenge in Reassessment: From TOLA to Section 292BC of the Income Tax Act, 1961
Overview In the wake of the significant increase in reassessment notices following 2021, the jurisdictional validity of such notices—particularly under Section 151—has become a major source of legal d...
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Ensuring Finality in Tax Assessments: A Case for the ‘Taxpayer Certainty Year’ under the Income-Tax Act, 2025
Introduction: The Perpetual Uncertainty for Indian AssesseesIndia’s new Income-Tax Act, 2025, which superseded the previous 1961 regime from 1 April 2026, was introduced with the promise of greater si...
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GAAR and PPT in Indian Tax Law: Harmonization or Divergence?
Introduction: Tax Planning and Anti-Avoidance MeasuresTaxation is a mandatory fiscal obligation in every jurisdiction. While legitimate tax planning is permitted within the boundaries of the law, the...
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Provisions of Search and Seizure under the Income Tax Act, 2025: A Comparative Analysis with the Income Tax Act, 1961
Introduction to Search and Requisition ProvisionsThe Income Tax Act, 2025, has streamlined and expanded the framework for search and seizure operations, which were previously governed by sections 132...