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The Conversion Doctrine: Legal Validity of Converting a Section 133A Survey into a Section 132 Search under the Income Tax Act
Introduction The Indian tax administration system operates through distinct investigative mechanisms designed to detect and prevent tax evasion. Among these, the Income Tax Act, 19
Section 133A of the Income Tax Act Post Finance Act 2022: Survey Approval Framework & Legal Challenges
Introduction The Finance Act 2022 introduced significant amendments to Section 133A of the Income Tax Act, 1961, fundamentally altering the landscape of survey operations conducted
Section 14A Disallowance – Understanding The Fundamental Principle And Rule 8D Computation
1. INTRODUCTION & CONTEXT Why This Matters For any business investing in tax-exempt securities (dividend-yielding shares, mutual funds generating exempt income, Section 10 inve
Section 271(1)(c) Penalty in Detail: Concealment vs. Inaccuracy and the Requirement for Intentional Wrongdoing
Introduction: A Question of Two Essentials and Intentional Wrongdoing Section 271(1)(c) of the Income Tax Act, 1961, stands as one of the most litigated, contested, and misapplied
Penalty and Criminal Prosecution under Income Tax Act: Understanding the Hierarchical Relationship with Assessment Orders
How Penalty Cancellation Automatically Quashes Criminal Prosecution and the Supreme Court’s Doctrine of Simultaneity Introduction: The Paradox of Simultaneous But Interconnec
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
Cross-Border Taxation and India’s GAAR: Conflict or Coherence?
Introduction In an era of globalized business operations and sophisticated cross-border tax planning, nations worldwide have been compelled to develop robust anti-avoidance framewo
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
Faceless Assessment Scheme in India: Constitutional Challenges
Introduction The introduction of the Faceless Assessment Scheme in India represents one of the most significant structural reforms to the country’s tax administration system
Unveiling the Shadow Economy: Understanding Undisclosed Sources of Income and Its Tax Implications
Introduction: Undisclosed Sources of Income in the Indian Tax System In the complex world of taxation, one of the most challenging aspects for tax authorities is dealing with undis
