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Income Tax Case Law

ITAT Mumbai Denies Tax-Neutral Demerger: Why the Holding Company’s Shares Weren’t Enough

Case Law / August 9, 2026 / Corporate Restructuring, Demerger, Income Tax, Income Tax Case Law, Income-tax Act 1961, ITAT, Section 2(19AA)

ITAT Mumbai denies ₹240+ crore in carried-forward losses in Sterling Holiday Resorts Ltd. v. DCIT, holding that a holding company’s shares cannot substitute for the resulting company’s own share issuance under Section 2(19AA) of the Income-tax Act.

ITAT Mumbai Denies Tax-Neutral Demerger: Why the Holding Company’s Shares Weren’t Enough Read Post »

Income Tax case law: 271C TDS penalty distinction

Case Law, Income Tax

Income Tax Case Law Roundup: The 7-Day SCN Rule and the Section 271C TDS Penalty Distinction

Case Law, Income Tax / August 4, 2026 / Faceless Assessment, Income Tax Case Law, Natural Justice, Section 271C, TDS Penalty

Two rulings this week reshape how faceless assessment notices and TDS penalty proceedings should be handled: a mandatory 7-day SCN window, and a sharpened line between non-deduction and delayed deposit under Section 271C.

Income Tax Case Law Roundup: The 7-Day SCN Rule and the Section 271C TDS Penalty Distinction Read Post »