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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
