DTAA Compliance Gets Stricter: Form 10F Now Mandatory for All Treaty Claims   A significant procedural shift has been introduced under the Income-tax Act, 2025 and Income-tax Rules, 2026, effective from 1st April 2026. The change revolves around a seemingly simple document-Form 10F (now replaced by Form 41)-but its impact on international taxation compliance is far-reaching….

Reassessment Fails Without 143(2): Delayed Return in response to notice under section 148 Cannot Be Ignored     In a crucial ruling reinforcing procedural safeguard in reassessment proceedings, the Tribunal has held that a return filed in response to notice under Section 148 cannot be treated as non-Est merely because it is delayed. More importantly, it…

Section 69A Cannot Be Invoked on Explained Cash Re-Deposits: ITAT Clarifies Law   In an important ruling reinforcing the correct scope of deeming provisions, the Tribunal in Pradeep Patni vs ITO (ITA No. 687/Ind/2025) has held that Section 69A applies only when unexplained money is found with the assessee and not when deposits are duly explained. The decision…

No Tax on Old Deal done prior to enactment of law: ITAT Rules Section 56(2)(x) Cannot Apply Retrospectively   In a significant ruling protecting taxpayers from retrospective taxation, the Tribunal in Rinki Singh (ITA No. 56/Ran/2025) has held that Section 56(2)(x) cannot be invoked where the original property purchase agreement predates the provision, even if the sale deed…

Virtual Presence Is Not Physical Presence: Bombay High Court Draws a Clear Boundary   In a landmark ruling with far-reaching implications for cross-border taxation, the Bombay High Court in Benteler Automotive China v. ACIT has addressed a fundamental question of the digital age—does virtual presence amount to physical presence in India for tax purposes? The answer, delivered…