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Bridging the Transition Gap in Section 195: Ensuring Fair Taxation under the Income Tax Act, 2025
Introduction: Understanding Key Provisions for Return FilersTax compliance requires assessees to be aware of pivotal provisions that impact the way unexplained incomes are taxed. Section 107 of the In...
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Unaddressed Shortcomings in the Income-tax Act, 2025 from a Mergers and Acquisitions Standpoint
OverviewThe Income-tax Act, 2025 (ITA, 2025), which supersedes the long-standing Income-tax Act, 1961 (ITA, 1961), has been operational since April 1, 2026. The principal aim of this legislative overh...
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Trust Registration and Donor Approval Under the Income-tax Act, 2025: Key Provisions and Compliance Roadmap
Introduction: Shifting Landscape for Charitable TrustsCharitable organisations in India have long benefitted from special tax exemptions, provided they met the statutory requirements. With the coming...
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Deduction of Interest Income for Cooperative Societies under Section 80P(2)(d) and Its Successor Section 149: The Effect of Legislative Changes and Judicial Interpretation
Overview: Cooperative Societies and Their Tax BenefitsCooperative societies in India have traditionally benefited from specific tax incentives, notably under Section 80P of the Income-tax Act, 1961. T...
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Allowability of Deductions for Vastu Consultancy Expenditure under the Income-tax Act, 2025
Overview of Deduction Principles under Section 34Section 34 of the Income-tax Act, 2025, which is a re-enactment of the earlier Section 37, sets forth the general framework for claiming business-relat...
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Interpretational Challenges in Determining ‘Cost of Acquisition’ under Section 49(1)(iii)(c) and Explanation to Section 55(2), Income-tax Act, 1961
OverviewCapital gains taxation remains one of the more contentious areas within Indian tax law, often leading to disputes over the correct interpretation of statutory provisions. Central to several of...
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Analysis of the Interrelationship Between Section 5(2) and the Provisions Relating to Unexplained Credits: A Non-Resident’s Viewpoint
OverviewNon-resident assessees frequently confront situations where the Assessing Officer (AO) invokes additions under section 68 or 69 of the Income Tax Act, 1961, or under the corresponding sections...
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Tax Implications of Share Buy-Backs under Section 56(2)(x): Examination of the Delhi High Court’s Globe Capital Market Ltd. Decision
Introduction: The Evolving Tax Landscape Around Share Buy-BacksRecent years have seen increased scrutiny of share buy-back arrangements, especially concerning their tax treatment under the Income-tax...
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Private Discretionary Trusts and the Surcharge Dilemma: A Contemporary Analysis
Understanding Trusts in Indiai) What is a Trust?A trust refers to a legal arrangement where a person, known as the settlor (or author/creator), transfers property or assets to a trustee, who then mana...
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Resolving the TDS Dilemma for Non-Resident Partners: Section 194T Versus Section 195
Background: Overlapping TDS Regimes and Legislative AmbiguityThe Finance (No. 2) Act, 2024, brought in section 194T to the Income-tax Act, 1961, effective from 1 April 2025. This provision obliges par...
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Obligation of Legal Heirs to Explain the Source of the Source under Section 68: A Comprehensive Review
IntroductionIn professional practice, a recurring question arises regarding whether legal heirs must establish the "source of the source" of credits in the books of a deceased assessee, especially in...
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Reimagining India’s Advance Pricing Agreement (APA) Landscape: Swifter Resolutions and Enhanced Compliance
Introduction to Advance Pricing Agreements: Designing Tax CertaintyAdvance Pricing Agreements (APAs) were formally introduced under the Finance Act, 2012, to bring predictability and uniformity in the...
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Significant Income Tax Reforms Effective from 1st April 2026
IntroductionNumerous amendments to income tax laws in India have come into force starting 1st April 2026, marking the commencement of the Tax Year 2026-27. These reforms center around the enforcement...
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Impact of Section 292BC on the Legal Framework of Section 153D: An Analytical Overview
1. Legislative Framework(i) Requirement of Prior Approval under Section 153DSection 153D of the Income Tax Act mandates that assessment or reassessment orders in search or requisition cases, issued by...
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Presumptive Taxation for Businesses under the Income-tax Act, 2025: An In-depth Review
OverviewPresumptive taxation was designed as a compliance-friendly approach for small businesses, enabling assessees to declare income at a fixed percentage of turnover, thus removing the necessity to...
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The End of the 1962 Regime: Key Strategies and Transitional Dynamics Under the Income-tax Rules 2026
1. Overview of the Regulatory ShiftThe Central Board of Direct Taxes (CBDT) has brought forth the new Income-tax Rules, 2026, which will become operative only with the enforcement of the Income-tax Ac...
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In-depth Overview of Key Modifications in ITR Forms for Assessment Year 2026-27
The Central Board of Direct Taxes (CBDT) has issued the latest versions of ITR Forms 1 to 7, along with ITR-V and ITR-U, for Assessment Year 2026-27, covering income earned during the Previous Year 20...
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Deadline for Imposing Penalties under Income Tax Law: An Analysis
Introduction: Judicial Perspective and Legislative IntentThe Supreme Court, in the landmark case of ITO v. Ch. Atchaiah (1996) 218 ITR 239 (SC), established that the rightful assessee is obligated to...
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Outward Remittance Tax Compliance in India: Transition from Forms 15CA/15CB to Forms 145/146
Overview of the New Compliance RegimeFrom 1 April 2026, India’s cross-border remittance compliance landscape will undergo a significant overhaul. The long-standing Forms 15CA and 15CB, integral to the...
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In-depth Overview of Amendments in the Finance Bill 2026 as Passed by Lok Sabha
On March 25, 2026, the Lok Sabha approved the Finance Bill 2026 (hereafter, 'Finance Bill (Lok Sabha)'), introducing several key changes to the original proposals. The bill, while retaining most of th...