SEO Title: Section 147A Reassessment Notices: Supreme Court Remands JAO vs FAO CasesURL Slug: section-147a-reassessment-notices-supreme-court-remandMeta Description: Section 147A reassessment notices face fresh High Court scrutiny after Supreme Court remands JAO vs FAO cases post Finance Act 2026 amendment. Introduction Section 147A reassessment notices have become one of the most important reassessment litigation issues under the…

Foreign Tax Credit Form 67 has become an important compliance issue for Indian resident taxpayers earning foreign income. Many taxpayers pay tax outside India on foreign salary, dividends, ESOPs, RSUs, consultancy income or other overseas receipts. When the same income is also taxable in India, foreign tax credit helps avoid double taxation. A recent ITAT…

The Mumbai ITAT has delivered an important taxpayer-friendly ruling in Sophia Rick v. ITO, holding that an employee cannot be denied credit of TDS merely because the employer deducted tax from salary but failed to deposit the same with the Government. The case involved AY 2019-20, salary income of about ₹18.41 lakh, TDS credit claimed…

In Narayanan Sundaramahalingam Rajkumar v. ACIT, ITAT Chennai held that agricultural land falling within the prescribed population and aerial-distance limits under section 2(14)(iii)(b) is taxable as a capital asset, even if it is agricultural in revenue records. The Tribunal also gave relief on alleged on-money by restricting the addition to the admitted cash component and…

Union Budget 2026-27 has brought an important compliance shift through direct tax proposals for rationalising penalty and prosecution. The official PIB release states that assessment and penalty proceedings are proposed to be integrated, pre-payment is proposed to be reduced from 20% to 10% of core tax demand, and updated returns may be allowed even after…

The ITR filing season for AY 2026-27 is important because the Income Tax Department has made simplified return forms more useful for eligible taxpayers. The return for AY 2026-27 covers income earned during FY 2025-26, and the official transition FAQ clarifies that such filing continues under the Income-tax Act, 1961. The major change is that…

SEBI has approved a major set of capital market reforms at its Board meeting held on 19 June 2026. The official SEBI press-release listing records the item as PR No. 35/2026. (Securities and Exchange Board of India) The biggest reform is the reintroduction of open market buybacks through stock exchanges from 1 August 2026. Under…

A timing mismatch between income recognition and TDS deduction has long created practical hardship for taxpayers. In many cases, an assessee offers income to tax in one assessment year, but the deductor deducts and deposits TDS in a subsequent year. As a result, credit appears in Form 26AS/AIS for a different year, while the income…

Cryptocurrency taxation in India is now governed through the framework of Virtual Digital Assets. The term is wide enough to cover crypto tokens, NFTs and similar digital assets that are transferable, storable or tradeable electronically. Indian currency and foreign currency are excluded from this definition.  The core tax rule is simple but strict: income from…

Supreme Court on Reopening u/s 147/148: Sanand Properties Ruling and the Dilution of “Change of Opinion” Defence Landmark Ruling: Sanand Properties P. Ltd. vs JCIT — 2026 INSC 472 The Hon’ble Supreme Court in Sanand Properties P. Ltd. vs Joint Commissioner of Income Tax, Range 6 & Ors., Civil Appeal No. 9107 of 2012 with…

Auditor Withdrawal and Bona Fide Belief: Kerala High Court Condonates 676-Day Delay in ITAT Appeal Background of the Case – Mallelil Industries Pvt. Ltd. v. Principal CIT, Kottayam, ITA No. 51 of 2026, Delay condonation in tax appeals often involves a difficult balance. On one side is the law of limitation. On the other side…