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Non-Compete Fee Can Be Deducted As Revenue Expenditure Under Section 37(1) Income Tax Act: Supreme Court Clarifies Long-Standing Controversy
Introduction The Indian Supreme Court has recently delivered a landmark judgment that has far-reaching implications for corporate taxation in the country. In Sharp Business System
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
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
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
The Suo Moto Disallowance Trap – When Your Own Return Becomes Evidence Against You
1. INTRODUCTION: THE SELF-INCRIMINATION PARADOX The Core Tension There’s a peculiar paradox in Indian tax law: the more transparent and self-critical you are in your tax retu
Implications of Section 281 of the Income Tax Act for Companies and Individuals
Introduction: Understanding the Protective Framework The Income Tax Act of 1961 stands as the cornerstone legislation governing direct taxation in India, establishing a framework t
Income Tax Department Imposes ₹23 Crore Penalty on ACC Limited: A Comprehensive Analysis of Tax Compliance and Penalty Provisions
Introduction The Income Tax Department recently imposed a substantial penalty totaling ₹23.07 crore on ACC Limited, one of India’s leading cement manufacturing companies cu
TDS Defaults: Legal Remedies and Penal Consequences for Companies
Introduction Tax Deducted at Source (TDS) forms a critical component of India’s direct tax collection mechanism, designed to ensure the timely and consistent flow of revenue
Taxation System in India: Legal Framework and Regulatory Structure
Introduction The taxation system in India represents one of the most vital components of the nation’s economic architecture, serving as the primary mechanism through which th
