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Gujarat High Court Clarifies the Law on Reassessment vs Search Assessments: Section 147 Cannot Bypass Section 153C

Gujarat High Court Clarifies the Law on Reassessment vs Search Assessments: Section 147 Cannot Bypass Section 153C   The interplay between reassessment provisions under sections 147/148 and search-related provisions under sections 153A and 153C has been a recurring source of litigation. A recent decision of the Hon’ble Gujarat High Court has now brought much-needed clarity by drawing…

Limited Scrutiny Means Limited Powers: ITAT Delhi Quashes Section 263 Revision in Harun Ali vs Pr. CIT

Limited Scrutiny Means Limited Powers: ITAT Delhi Quashes Section 263 Revision in Harun Ali vs Pr. CIT   A recent decision of the Hon’ble Income Tax Appellate Tribunal, Delhi Bench in Harun Ali vs Principal Commissioner of Income Tax (ITA No. 3444/Del/2025, Assessment Year 2015–16) once again reinforces a crucial but often misunderstood principle of income-tax law: a limited scrutiny assessment…

No Addition under Section 69A on Repayment of Loan Already Accepted as Genuine: Key Ruling of ITAT Delhi

No Addition under Section 69A on Repayment of Loan Already Accepted as Genuine: Key Ruling of ITAT Delhi   Hon’ble ITAT, Delhi, in the case of M/s Gehna Impex Pvt. Ltd. v. Jt. CIT for A.Y. 2016-17 (ITA No. 4499/Del/2025), wherein has been held that no addition under section 69A can be sustained where the…

Income-tax Act, 2025: Why the Change May Be More in Perception Than in Policy

Income-tax Act, 2025: Why the Change May Be More in Perception Than in Policy   The Income-tax Act, 2025 has naturally generated discussion, particularly where familiar provisions appear to be rewritten with stronger language and new section numbers. On closer reading, however, the Act appears less about altering tax policy and more about restructuring and…

Income-tax Act, 2025 and Unexplained Income: Old Sections 68 to 69D vs New Law – Change in Substance or Just Structure?

Income-tax Act, 2025 and Unexplained Income: Old Sections 68 to 69D vs New Law – Change in Substance or Just Structure?   The introduction of the Income-tax Act, 2025 has triggered widespread discussion across tax portals, professional circles, and business forums. At first glance, the Act appears to be a major overhaul, with renumbered sections,…

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