Income Tax Cases
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3 Key Takeaways of Recent ITAT Ahmedabad Deemed Dividend Case Law of 2025
- October 2, 2025
- Posted by: Amit Mundhra CA
- Category: Income Tax Cases
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Deemed dividend case law have repeatedly confirmed that Section 2(22)(e) should be applied strictly. In a recent ruling, the ITAT Ahmedabad reaffirmed that TDS under Section 194 is attracted only where dividend is paid to a shareholder, and not on genuine inter-corporate loans given for commercial purposes.
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TDS on Purchase of Software from Outside India u/s 195
- July 6, 2025
- Posted by: Amit Mundhra CA
- Category: Income Tax Cases
The Supreme Court in the Engineering Analysis case ruled that payments for software purchases without transfer of copyright are not ‘royalty’ and hence not subject to TDS under Section 195. This landmark decision brings clarity on TDS applicability for software, cloud services, and cross-border transactions.
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Key Judicial Pronouncements – Mechanical Approvals in Section 148 Notices
- May 10, 2025
- Posted by: Amit Mundhra CA
- Category: Income Tax Cases
This article covers important court judgments where reassessment notices under Section 148 were struck down due to mechanical approvals under Section 151. It highlights how courts are emphasizing the need for independent satisfaction rather than rubber-stamp approvals, with detailed case law analysis from Delhi, Bombay, and Gujarat High Courts.
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Reassessment Under Section 148 – Old vs New Regime: Life After the Rajeev Bansal Verdict
- April 20, 2025
- Posted by: Amit Mundhra CA
- Category: Income Tax Cases
What happens when the Income Tax Department issues reassessment notices under Section 148 without following the proper law? This article explains the key changes under the old and new reassessment rules, the Supreme Court’s verdict in Rajeev Bansal, and how recent ITAT rulings are cancelling time-barred or invalid notices.