Has the Supreme Court Quietly Diluted the “Change of Opinion” Doctrine? A Critical Look at Sanand Properties Pvt. Ltd. vs. JCIT   The Supreme Court’s recent ruling in Sanand Properties Pvt. Ltd. vs. JCIT [(2026 INSC 472) dated 12.05.2026], authored by Hon’ble Justice J.B. Pardiwala, may prove to be one of the most consequential reassessment judgments delivered…

Penalty Under Section 270A Invalid if AO Fails to Specify Exact Charge: Important ITAT Bangalore Ruling   In a significant ruling on penalty proceedings under Section 270A of the Income Tax Act, the Bangalore Bench of the Income Tax Appellate Tribunal (ITAT Bangalore) has held that penalty proceedings become legally unsustainable where the Assessing Officer…

Substance Over Form: ITAT Mumbai Reaffirms Appellate Powers to Entertain New Claims Without Revised Return     In a significant ruling reinforcing the principle that taxation must ultimately reflect the correct legal liability and not procedural rigidity, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT Mumbai) has held that appellate authorities can entertain…

NRI Selling Property in India? Beware: TDS Rules Have Changed Under the New Income Tax Act, 2025   The sale of immovable property by Non-Resident Indians (NRIs) has always been a compliance-sensitive area. While most taxpayers are familiar with the old Section 195 of the Income-tax Act, 1961, the introduction of the Income-tax Act, 2025…

ITAT Indore Drops Penalty Under Section 271AAC: “When Quantum Fails, Penalty Cannot Survive”     In an important reaffirmation of a settled principle of tax jurisprudence, the Indore Bench of the Income Tax Appellate Tribunal (ITAT Indore) has held that penalty proceedings under Section 271AAC cannot survive independently once the underlying quantum assessment itself has…