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Representation by Authorised Representative in Income Tax Proceedings: A Detailed Overview
Right of Assessee to be Represented in Income Tax Proceedingsi) Appearance through Authorised RepresentativeUnder Section 515 of the Income Tax Act, 2025 (which corresponds to Section 288 of the Incom...
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Transitioning to the Income-tax Act, 2025: New Challenges for Professionals in Bookkeeping and Compliance
Introduction: Overhaul of Indian Income Tax LegislationThe Central Board of Direct Taxes (CBDT), through its Directorate of Income Tax (Organisation and Management Services), has published a detailed...
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Distinguishing Revenue Sharing and Profit Sharing in AOPs: Taxability of Members’ Income in Light of Sanand Properties Case
Introduction and Factual MatrixIn the landmark case involving Sanand Properties Pvt. Ltd. (SPPL), the Supreme Court addressed pivotal issues regarding taxation of income received by members of Associa...
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Section 50CA and Bona Fide Transfers of Unquoted Shares: Applicability and Interpretation
IntroductionSection 50CA of the Income-tax Act, 1961, introduced through the Finance Act, 2017 and effective from 1 April 2018, establishes a mechanism for determining the full value of consideration...
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Taxation of Hoarding Income – Standard Deduction Eligibility
1. Introduction: Taxation of Hoarding Income – Standard Deduction EligibilityIn the context of Indian income tax law, a recurring issue arises regarding the treatment of rental income received from th...
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The Endurance of India’s 90+ DTAA Notifications Post-ITA 2025: Navigating Transitional Uncertainties in Treaty Implementation
Introduction: The Quiet Transition Dilemma and Its Massive Fiscal ImpactIndia’s Income-tax Act, 1961 was repealed with effect from 1 April 2026 by Section 536(1) of the Income-tax Act, 2025 (ITA 2025)...
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A New Digital Approach for Non-Taxable Income Declaration: Replacing Form 121 with Online Submission on the Income Tax e-Filing Portal
Introduction and OverviewThe current procedure for declaring non-taxable income to seek exemption from Tax Deducted at Source (TDS) relies heavily on the use of Form 121 (formerly known as Forms 15G a...
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A Complete Overview of the Liberalised Remittance Scheme (LRS) Post-Finance Act 2026
1. Introduction to the Liberalised Remittance SchemeThe Liberalised Remittance Scheme (LRS) allows Indian residents to remit funds overseas for a variety of purposes. With the recent amendments brough...
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A Practitioner’s Guide to Startup Taxation under the Income-tax Act, 2025: Section 140 (Formerly Section 80-IAC) and Key Allied Provisions
Overview of Legislative ChangesThe Income-tax Act, 2025 (Act 30 of 2025) took effect from April 1, 2026, replacing the long-standing Income-tax Act, 1961. This new Act streamlines the legal framework...
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A Tale of Two Tax Tigers: Navigating the Boundaries of Indian Tax Law
Introduction: The Role of Taxation in SocietyJustice Oliver Wendell Holmes of the US Supreme Court once remarked, “I like to pay taxes; with them, I buy civilization.” Taxes are the backbone of govern...
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Taxation Aspects of Wipro Limited's 2026 Share Buy-Back Programme
IntroductionOn 16 April 2026, Wipro Limited unveiled a significant share repurchase plan, proposing to acquire up to 600 million fully paid equity shares, amounting to roughly 5.72% of its paid-up sha...
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Identifying a Key Procedural Gap in ITAT Rectification Timeline: A Case Study
Introduction and BackgroundThe author, a chartered accountant, recently represented an assessee in an ongoing dispute involving income tax and transfer pricing adjustments under the Income-tax Act, 19...
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Bombay High Court Clarifies: EOU Profit Deductions Cannot Be Arbitrarily Capped by Comparing with Domestic Sister Concerns
IntroductionThe recent decision of the Bombay High Court in the case of Pragati Aroma Oil Distillers Pvt. Ltd. v. DCIT (IT Appeal No. 502 of 2015, dated 23 April 2026), highlights a significant clarif...
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Reframing the Defence of “Fiduciary Capacity” under the Amended Benami Transactions Law
Introduction: Evolution of the Benami Law and the ‘Fiduciary Capacity’ ExceptionThe landscape of benami transactions in India underwent a significant shift with the amendment of the Prohibition of Ben...
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Self-Imposed Encumbrances and Capital Gains Taxation under ITA 2025 — Statutory Analysis and Judicial Trends
OverviewCapital gains taxation in India fundamentally operates on the principle that the taxable gain is the difference between the sale consideration and the cost incurred by the assessee in acquirin...
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The Reassessment Dilemma Under the Income-Tax Act, 2025: Navigating the Legacy of Section 148 Notices After Repeal
1. Introduction: The Challenge of Transitioning Legacy Reassessment ProceedingsOn 1 April 2026, the Income-Tax Act, 1961 was repealed by virtue of Section 536(1) of the Income-Tax Act, 2025, ushering...
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Revisiting ESOP Repricing in India: Legal Landscape and Practical Insights
Introduction: ESOPs as Employee IncentivesEmployee Stock Option Plans (ESOPs) are primarily designed by companies to reward and motivate employees, aligning their interests with company growth. The in...
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Policy Shifts in the Income Tax Act, 2025: Analysis of Capital Gains Provisions
1. IntroductionThe transition from the Income Tax Act, 1961 (ITA, 1961) to the Income Tax Act, 2025 (ITA, 2025) was primarily aimed at making tax legislation more accessible and comprehensible for the...
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Impact of Section 147A: Has the JAO vs. Faceless Assessment Controversy Been Resolved for Pre-1 April 2026 Assessments?
Introduction and Legislative BackgroundThe Finance Act, 2021 brought transformative changes to the reassessment procedure under the Income-tax Act, 1961, specifically by revamping Sections 147 to 151....
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Communication Window Facility in Income Tax Appeals
1. Introduction: Communication Window Facility in Income Tax AppealsThe Enablement of Communication Window, referred to as "the window," is a digital solution implemented by the Income Tax Department,...