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Case Law

Supreme Court: A CBDT Circular Cannot Bind the Courts — Export Quota Premium Denied Section 80HHC Benefit

In Orient Crafts Ltd. & Samtex Fashions Ltd. v. CIT, the Supreme Court has held that a CBDT circular equating export-quota sale premiums with Section 28(iiia)-(iiic) export income cannot bind the courts, denying the connected Section 80HHC deduction.

20 Sept 20267 min read

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Income Tax

CBDT Removes Arrest and Detention From Tax Recovery, Extends Valuer/Practitioner Registration Deadline to March 2027

The CBDT has notified the Income-tax (Fourth Amendment) Rules, 2026, removing arrest and detention as a mode of tax recovery under Rule 225 and extending the Valuer and Authorised Income-tax Practitioner registration deadline to 31 March 2027.

20 Sept 20267 min read

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Case Law

Supreme Court Stays the Section 147A Ruling: The Reassessment Fight Is Frozen Until December

A stay usually means one thing wins and the other loses. This one doesn’t — the Supreme Court has frozen both the Section 147A ruling and the reassessment proceedings riding on it, until 3 December.

19 Sept 20267 min read

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Case Law

Once Settled, Always Settled: Supreme Court Shuts the Door on Reopening ITSC Orders Through Reassessment

Settlement is supposed to mean something is actually settled. That was, at bottom, the question the Supreme Court answered on […]

18 Sept 20267 min read

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Case Law

Centre Challenges the Section 147A Ruling: The Reassessment Fight Moves to the Supreme Court

Six days is not very long, as legal timelines go. On 11 September, the Punjab & Haryana High Court struck […]

18 Sept 20266 min read

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Case Law

A Demand Cannot Stand on an Appellate Order CESTAT Has Already Set Aside — Delhi HC (Welspring Universal)

The Delhi High Court has quashed a ₹76.72 lakh demand-cum-show-cause notice and confirmation order because the adjudicating authority relied on a Commissioner (Appeals) order that CESTAT had already set aside.

16 Sept 20265 min read

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Case Law

DGGI’s Section 122 Jurisdiction Upheld, Pre-Deposit Transition Rule Reaffirmed — Delhi HC (Rohit Garg)

In a batch of 629 writ petitions worth over ₹227 crore, the Delhi High Court has upheld DGGI officers’ jurisdiction to issue Section 122 GST penalty notices, and reaffirmed that the amended 10% pre-deposit rule doesn’t reach back to pre-October-2025 show cause notices.

16 Sept 20268 min read

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Case Law

Delhi HC: Same Income, Taxed Twice, Six Years Apart — the Court Fixed It

The Delhi High Court has permitted a belated revised return under Section 119(2)(b) after a taxpayer, through no fault of its own, ended up paying tax on the same ₹7.58 crore of interest income twice, after the deductor silently revised Form 26AS.

15 Sept 20265 min read

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Case Law

HDFC Life: A ₹942 Crore GST Notice Just Grew Into a ₹3,365 Crore Confirmed Demand

The Commissioner (Appeals-III), CGST & Central Excise, Mumbai has confirmed a ₹3,365 crore GST demand and penalty against HDFC Life Insurance, rooted in a sector-wide DGGI probe into input tax credit claimed on agent-commission-linked invoices.

15 Sept 20265 min read

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GST Updates

GSTN’s New Geo-Coordinate Registration: Smarter Portal, Same Professional Responsibility

GSTN’s geo-coordinate based jurisdiction auto-population is live from 1 September 2026. It reduces manual errors — but the taxpayer’s responsibility for correct address, geo location and jurisdiction remains unchanged.

15 Sept 20265 min read

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GST Updates

Corporate Guarantee Is Taxable — But the Gujarat High Court Has Drawn a Very Important Line

Gujarat HC confirms corporate guarantees between holding and subsidiary are taxable under GST — but Rule 28(2)’s 1% formula cannot apply before 26 October 2023, and ‘whichever is higher’ has been read down.

15 Sept 20267 min read

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Income Tax

CBDT Introduces SFT-2517: The Invisible Hand That’s About to Pre-Fill Your Client’s Capital Gains

CBDT’s Notification No. 1 of 2026 prescribes SFT-2517 for depository participants — here’s what it means for your clients’ ITR pre-fill, AIS reconciliation, and your capital gains practice.

15 Sept 20264 min read

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Act Explainers

Form 132 and Section 425: The New Act’s Numbers Behind This Week’s Two Deadlines

Today’s TDS-certificate deadline (Form 132) and tomorrow’s advance-tax instalment both trace to freshly renumbered Income-tax Act, 2025 provisions — the same obligations, under new section numbers practitioners should get right.

14 Sept 20264 min read

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Case Law

ITAT Mumbai: A Bitcoin Reassessment Fell Apart Over Who Signed the Approval, Not the Bitcoin

ITAT Mumbai has quashed a reassessment that added Rs 1.24 crore in bitcoin-sale proceeds as unexplained investment, after finding the reopening — beyond three years — was sanctioned by the wrong authority under Section 151(ii).

14 Sept 20265 min read

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Case Law

Delhi HC: An Assessing Officer Can’t Ignore a Reply That’s Already on the Record

The Delhi High Court has quashed a Section 148A(d) reassessment order because the Assessing Officer had the taxpayer’s reply on record — uploaded before the order was passed — and simply didn’t consider it.

14 Sept 20265 min read

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Income Tax

Madras HC: Suspicion Cannot Replace Proof — Rs 70.95 Crore Bogus LTCG Addition Deleted

Madras HC dismisses Revenue’s appeals in CIT Chennai v. Sohanraj Uttamchand — upholds ITAT deletion of Rs 70.95 crore LTCG addition. Steep share-price rise alone, without taxpayer-specific evidence, cannot make LTCG bogus.

14 Sept 20266 min read

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GST Updates

No ‘Reason to Believe’: Karnataka HC Quashes GST Registration Cancellation Built on a Fabricated Field Report

The Karnataka High Court has quashed the cancellation of two GST registrations as “fake,” holding that field-verification reports containing an unrelated property’s photograph and a blank report cannot meet the statutory “reason to believe” standard.

13 Sept 20265 min read

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Income Tax

“Change of Opinion” Reaffirmed: Bombay HC Quashes a Six-Year-Late Reassessment on a Settled Section 54F Claim

The Bombay High Court has quashed a reassessment notice issued six years after a Section 54F capital gains claim was accepted, holding that an Assessing Officer need not discuss every issue for the law to treat it as examined.

13 Sept 20265 min read

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GST Updates

No More GST Registration Without Biometric Aadhaar: Delhi High Court’s Nationwide Direction

The Delhi High Court has directed that no GST registration be granted anywhere in India without biometric Aadhaar authentication, responding to over ₹28,000 crore in fraud-linked tax evasion detected across two years through fake registrations.

13 Sept 20264 min read

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Income Tax

Section 147A Struck Down: Punjab & Haryana High Court Reopens the JAO Reassessment-Notice Fight

The Punjab & Haryana High Court has struck down Section 147A of the Income Tax Act as unconstitutional, reopening the fight over reassessment notices issued by Jurisdictional Assessing Officers rather than the faceless centre — with roughly ₹17 lakh crore in disclosed fiscal exposure and 500+ writ petitions directly affected.

13 Sept 20266 min read

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