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Comprehensive Treatise on Capital Gains Tax on the Sale of Agricultural Land in India
Chapter 1: Constitutional and Statutory Genesis of Agricultural Taxation The taxation of agricultural land in India is not merely a matter of fiscal statute but a subject deeply ro
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
Cloud Data Access During Income Tax Surveys in India: Legal Framework & Jurisdictional Challenges”
Introduction The digital transformation has fundamentally altered regulatory compliance and enforcement mechanisms in India. As organizations migrate to cloud-based infrastructure,
CBDT Office Memorandum 2025: Risk Management Strategy (RMS) Exemption for Search and Survey Cases – Streamlining Reassessment or Legal Loophole?
Introduction The Central Board of Direct Taxes (CBDT) issued an Office Memorandum on February 27, 2025, fundamentally altering how search and survey case information flows through
Survey Authorization for Entity A, Documents Found for Entity B: Section 153C Third-Party Tax Assessment, Section 292C Presumption Trap, and Group Company Liability
Understanding the Jurisdictional Anomaly in Tax Assessments During tax enforcement proceedings, the Income Tax Department often encounters a peculiar situation where survey or sear
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
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
