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Commissioner of Income Tax vs. East India Syntex Limited: A Comprehensive Judicial Analysis on the Scope of Block Assessment Proceedings and the Classification of Capital vs. Revenue Expenditure

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 60
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Facts of the CaseThe assessee, East India Syntex Limited, is engaged in the manufacturing and production of polyester viscose blended yarn and 100% polyester yarn. For the block assessment period of 1.4.1988 to 14.10.1...

BLB Limited vs. Assistant Commissioner of Income Tax: Analysis of Reassessment Proceedings and the "Change of Opinion" Doctrine

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 86
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Facts of the Case The petitioner, BLB Limited, filed its income tax return for the Assessment Year (AY) 2003-04, declaring an income under Section 115JB of the Income Tax Act, 1961. During the original scrutiny asse...

Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of Rule 8D and Section 14A

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 75
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Facts of the CaseThe case consolidated three separate income tax appeals (ITA 277/2009, 460/2009, and 949/2009) concerning the assessment years 2004-05, 2000-01, and 2002-03. The dispute involved the Oriental Bank of C...

Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of the Non-Retrospective Nature of Rule 8D and the Application of Section 14A of the Income Tax Act

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 62
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Facts of the CaseThe appeals pertained to the assessment years 2000-01, 2002-03, and 2004-05 concerning the respondent, Oriental Bank of Commerce. The dispute arose regarding the application of Rule 8D of the Income Ta...

Commissioner of Income Tax vs. M/S DCM Shriram Consolidated Ltd: Applicability of Rule 8D and Mechanism of Disallowance Under Section 14A of the Income Tax Act, 1961

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 59
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Facts of the Case Nature of Appeal: The Appellant (Revenue) filed an appeal under Section 260A of the Income Tax Act, 1961, directed against the order of the Income Tax Appellate Tribunal (Tribunal) d...

M/s Genpact India vs. Assistant Commissioner of Income Tax: Legality of Unilateral Tax Refund Adjustments Under Section 245 and the Computational Treatment of Telecommunication Expenses for Deductions Under Section 10A of the Income Tax Act, 1961

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 70
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Facts of the Case The petitioner, M/s Genpact India, is engaged in rendering IT-enabled services and had established undertakings under the Software Technology Park Scheme (STPS). For the Ass...

Atsushi Yoshida vs. Assistant Commissioner of Income Tax: Validity of Reopening Assessment Under Section 147 Post Revised Return and Form 16 Alterations

Author
My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 78
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Facts of the Case Employment & Compensation: The petitioners were employees of M/s Tokio Marine and Nichido Fire Inc. Limited and were paid a tax-free salary in India, meaning the income tax compo...

Atsushi Yoshida Vs Assistant Commissioner of Income Tax: Scope of Income Tax Reopening Under Section 147/148 Post Expiry of Section 143(3) Scrutiny Timelines

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 66
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FACTS OF THE CASE The petitioners were expatriate employees of M/s Tokio Marine and Nichido Fire Insurance Company Limited. Under the specific terms of their employment contracts, they were paid a ...

Atsushi Yoshida vs. Assistant Commissioner of Income Tax (With Companion Petitions) Income Tax Act, 1961: Section 143(1), Section 143(2), Section 143(3), Section 133(6), Section 147, and Section 148.

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 93
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Facts of the Case The Assessees: The petitioners—Atsushi Yoshida, Yasunobu Fukuda, Shunzo Nagahama, Mazahiro Ogawa, and Toshiyuki Nakai—were employees of M/s Tokio Marine and Nichido Fire Inc. Lim...

Atsushi Yoshida Vs. Assistant Commissioner of Income Tax (and Connected Petitions) – Validity of Reopening Assessment Under Section 147/148 Following Section 143(1) Intimation in Cases of Revised Return and Salary Grossing-Up Claims

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My Tax Expert
01/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 60
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Facts of the Case Employment Terms: The five petitioners were expatriate employees of M/s Tokio Marine and Nichido Fire Inc. Limited. Under their specific terms of employment, they were paid a contrac...