Whatsapp
“Borrowed Satisfaction” in Section 148 Reopening: How RMS-Flagged Cases Are Being Quashed by Courts (2024-25 Update)
The reassessment provisions under the Income Tax Act have long been a battleground between taxpayers and revenue authorities. At the heart of recent litigation lies a critical ques
Section 14A/Mat Disallowances: Section 14A Disallowance: A Comprehensive Assessee Defense Strategy Across DRP, CIT(A), and ITAT
1. INTRODUCTION: THE ASSESSEE’S STRATEGIC LANDSCAPE Understanding the Asymmetry The relationship between the tax department and the assessee is inherently asymmetrical. The D
Department’s Perspective on Section 14A and MAT – The Revenue’s Case, Arguments & Strategic Position
1. INTRODUCTION: UNDERSTANDING THE REVENUE’S MINDSET The Department is Not Arbitrary A common misconception: The tax department is merely aggressive, trying to extract maximu
IND AS VS. IT ACT Reconciliation – When Accounting Profit Diverges From Taxable Income
1. INTRODUCTION: THE IND AS VS. IT ACT RECONCILIATION CHALLENGE The Problem Every CFO Faces Scenario: You’re presenting quarterly financial results to the Board: Finance Chie
Corporate Guarantees and Transfer Pricing – The Micro Ink Revolution
1. INTRODUCTION: THE GUARANTEE PRICING CONTROVERSY The Problem That Micro Ink Solved Pre-2016 Scenario: A multinational company (MNC) with Indian subsidiary structure: Parent compa
Section 115JB MAT vs Section 14A Rule 8D: Why Accounting Standards Prevail Over Tax Formulas
1. INTRODUCTION: THE CONCEPTUAL CLASH The Fundamental Tension At the heart of the Section 14A Rule 8D vs. Section 115JB debate lies a profound conceptual clash: On one side: The
Explanation 1 to Section 115JB – A Clause-By-Clause Analysis Of Book Profit Adjustments
1. INTRODUCTION: THE ARCHITECTURE OF BOOK PROFIT What is Explanation 1? Explanation 1 to Section 115JB(2) is the rulebook for computing book profit. It specifies, with surgical pre
Minimum Alternate Tax (MAT) Demystified – Book Profit vs. Taxable Income Explained
1. INTRODUCTION: THE TWIN TAX PROBLEM The Scenario That Started It All Imagine it’s the year 1997. You’re a wealthy Indian businessman running a successful manufacturin
Section 14A in MAT (Section 115JB): Can Rule 8d Disallowances Inflate Book Profits?
1. The Core Contradiction: Section 14A vs Section 115JB MAT The Core Contradiction Imagine this scenario: Company ABC Ltd. for AY 2023-24: Under Section 14A (Normal Computat
Block Assessment and Search Assessment: Complete Legal Guide with Procedures, Case Law & Checklists
Evolution, Statutory Comparison, Procedural Safeguards, and Practical Guidance for Tax Professionals Executive Summary: Two Regimes, One Principle India’s approach to taxing
