Section 263: The Complete Professional Commentary
Section at a Glance Parameter Position Under IT Act 1961 Power PCIT/CIT may revise orders prejudicial to Revenue Twin conditions Order must be (i) erroneous AND (ii) prejudicial to interests of Revenue Both conditions Must co-exist — satisfying one alone is insufficient Limitation period 2 years from end of FY in which order was passed […]
Section 270A: The Complete Professional Commentary
Section at a Glance Parameter Position Under IT Act 1961 Applicable from AY 2017-18 onwards Replaces Section 271(1)(c) — which continues for AYs up to 2016-17 IT Act 2025 equivalent Section 439 (penalty) + Section 440 (immunity) Penalty — under-reporting 50% of tax payable on under-reported income Penalty — misreporting 200% of tax payable on […]
Section 148A: The Complete Professional Commentary
Section at a Glance Parameter Position Under IT Act 1961 Inserted by Finance Act, 2021 (w.e.f. 01.04.2021) Latest amendment Finance (No.2) Act, 2024 — effective 01.09.2024 IT Act 2025 equivalent Section 281 Purpose Mandatory pre-notice procedure before Section 148 reassessment Core requirement Show-cause notice + opportunity to assessee + speaking order Time limit — income […]
Section 56(2)(x): Property Transactions and the Stamp Duty Trap
The Quick Reference Box Parameter Legal Position Who is taxed? Buyer — on difference between stamp duty value and consideration Trigger amount Difference must exceed ₹50,000 OR 10% of consideration Tax rate Normal slab rates under the head “Income from Other Sources” Safe harbour tolerance 10% of consideration (Finance Act 2020, from AY 2021-22) Is […]
Section 68 Cash Credits: When the AO’s Addition Fails
The Quick Reference Box Parameter Legal Position Who bears the burden? Assessee — primary burden to prove identity, creditworthiness, genuineness When does burden shift? After assessee produces adequate documentation What must AO do after burden shifts? Conduct independent inquiry — cannot sit back Withdrawn statement — sufficient to sustain addition? No — ITAT Mumbai 2026 […]
The Taxpayer Charter in IT Act 2025: Your Statutory Rights Against the Income Tax Department
Quick Summary Box Right Old Position (IT Act 1961) New Position (IT Act 2025) Fair and impartial treatment Administrative policy only Statutory guarantee Timely communication No specific statutory guarantee Statutory obligation on department Privacy of information Sec 138 (limited) Statutory + expanded scope Right to be heard Available in law; often violated Strengthened + personal […]
Updated Return (ITR-U) Extended to 48 Months: The Biggest Taxpayer Benefit in IT Act 2025 — Practical Guide
Quick Summary Box Parameter Old Position (Section 139(8A), IT Act 1961) New Position (Section 263, IT Act 2025) Window for filing updated return 24 months from end of relevant AY 48 months from end of relevant Tax Year Additional tax for filing at 12 months 25% of tax + interest 25% of tax + interest […]
Old Tax Regime vs New Tax Regime Under IT Act 2025: The Complete Comparison for Tax Year 2026-27
Quick Summary Box Parameter Old Tax Regime New Tax Regime (Section 202) Default regime No — must opt in Yes — default from Tax Year 2026-27 Basic exemption limit ₹2.5 lakh (general) / ₹3 lakh (senior) ₹4 lakh (all individuals) Rebate u/s 87A equivalent Up to ₹5 lakh total income Up to ₹12 lakh total […]
How to Cite Income Tax Sections in Court After 01 April 2026: The Practitioner’s Protocol for Two-Act Litigation
Quick Summary Box Forum Proceeding Type Governing Act Section to Cite AO Office Assessment for AY 2024-25 IT Act, 1961 Old section numbers CIT(A) Appeal for AY 2022-23 IT Act, 1961 Old section numbers ITAT Appeal for AY 2020-21 IT Act, 1961 Old section numbers High Court Reference for AY 2018-19 IT Act, 1961 Old […]
Faceless Assessment Gets Permanent Status: How IT Act 2025 Transforms India’s Tax Administration Forever
Quick Summary Box Parameter Old Position (IT Act 1961) New Position (IT Act 2025) Legal basis Administrative scheme (Section 144B) Statutory right (Chapter VIII — Sections 236–261) Can it be withdrawn? Yes — by executive order, without Parliament No — requires Parliamentary amendment Personal hearing right Discretionary / scheme-dependent Statutory right — codified NFAC as […]