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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/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
FCCB Redemption Premium – Deductibility, Accounting Treatment & Tax Implications
1. INTRODUCTION: WHAT ARE FCCBs & WHY REDEMPTION PREMIUM MATTERS The Corporate Reality Scenario: A renewable energy company (wind turbine manufacturer) needs ₹500 crores to b
DRP in Transfer Pricing Assessment: Appellate Rights and Lessons from Vodafone
1. INTRODUCTION: THE DUAL-ROUTE ASSESSMENT MECHANISM The Unique Feature of Transfer Pricing Assessment Unlike ordinary income tax assessments, transfer pricing assessments have a m
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
Assessment Order and Penalty Proceedings: Do Penalties Survive When the Assessment Is Quashed?
Introduction: The Doctrine of Parasitic Dependency Penalty proceedings under the Income Tax Act are inherently dependent on the validity of the principal assessment order from whic
Judicial Review of Advance Rulings under GST: Scope and Limitations
Introduction The introduction of the Goods and Services Tax (GST) in July 2017 marked a watershed moment in India’s indirect tax regime, consolidating multiple taxes into a u
Quashing of Assessment Order: A Case of Natural Justice
Introduction The assessment of income tax in India has undergone a transformative shift with the introduction of the faceless assessment regime under Section 144B of the Income Tax
