Income Tax

Section 271B penalty for a late tax audit report for AY 2026-27: half a percent of turnover or gross receipts, capped at Rs 1,50,000, and when section 273B reasonable cause can apply. The filing date itself is on the firm's CBDT extension note.

Authoritative direct tax charitable trust masterclass before ITAT Ahmedabad Benches: Defending delayed Form 10AB applications under CBDT extension circulars, defeating premature Section 115TD accreted tax levies post-Sardar Patel Trust, applying the Supreme Court AUDA cost-recovery test under Section 2(15), and reconciling Form 10BD donations by PGT & Associates.

Official Direct Tax Announcement: Central Board of Direct Taxes (CBDT) postpones statutory deadlines today. Due date for furnishing Tax Audit Reports under Section 44AB extended to OCTOBER 21, 2026, and Corporate/Audited Income Tax Returns (ITRs) extended to NOVEMBER 21, 2026 for AY 2026-27. Complete statutory analysis and penalty relief by PGT & Associates.

Historical AY 2025-26 guidance. CBDT Circular No. 15/2025 extended the audit report deadline to 10 November 2025 and the audited-case ITR deadline to 10 December 2025; it does not apply to AY 2026-27.

Authoritative search and seizure defense masterclass before ITAT Ahmedabad Benches: Reconciling seized cash with regular cash books, quashing Section 115BBE 78% tax rates post-Kailashben Chokshi statement retractions, and proving customary domestic Stridhan allowances by PGT & Associates.

Authoritative direct tax valuation defense masterclass before ITAT Ahmedabad Benches: Upholding the taxpayer's exclusive right to choose DCF over NAV under Rule 11UA(2), defeating hindsight projection variations post-Vodafone M-Pesa, and applying the 10% safe harbor margin under Section 50CA by PGT & Associates.

Authoritative direct tax penalty defense masterclass before ITAT Ahmedabad Benches: Quashing defective Section 274 show-cause notices post-SSA Emerald Meadows, dismantling 200% misreporting penalties under Section 270A(9), applying Section 270A(6) bona fide safe harbors, and securing Section 270AA statutory immunity by PGT & Associates.

Direct tax controversy masterclass before ITAT Ahmedabad Benches: Defending closely held companies against Section 68 share premium and unsecured loan additions, applying the binding Gujarat HC triple-test in Rohini Builders and Ayachi Chandrashekhar, quashing non-cross-examined accommodation entry reports, and defeating Section 115BBE 78% tax rates by PGT & Associates.

Direct tax controversy masterclass before ITAT Ahmedabad Benches: Defending against Section 148 notices post-Finance Act 2024, navigating the 3-year vs 5-year limitation divide, quashing mechanical Section 151 sanctions, and establishing lack of asset-backed escaped income exceeding ₹50 Lakhs by PGT & Associates.

Comprehensive direct tax search litigation masterclass before ITAT Ahmedabad: Applying the landmark Abhisar Buildwell Supreme Court & Saumya Construction Gujarat HC doctrine on unabated assessments, defending loose papers under Section 292C, and legally retracting coerced statements recorded under Section 132(4) by PGT & Associates.

Authoritative direct tax defense manual against revisionary jurisdiction: Quashing Section 263 revision orders before ITAT Ahmedabad Benches, establishing the boundary between lack of inquiry and inadequate inquiry, invoking the doctrine of merger, and protecting completed assessment orders by PGT & Associates.

Direct tax appellate masterclass from ITAT Ahmedabad Benches: Defending Section 68 share capital and premium additions with triple-test documentation, quashing Section 148/148A reassessments founded on borrowed satisfaction, applying Gujarat HC ratios in Corrtech and Claris, and search additions under Section 153A by PGT & Associates.

Direct tax litigation milestone manual: Navigating the National Faceless Assessment Centre (NFAC) protocol under Section 144B, responding to show cause notices with draft assessment orders, and High Court writ jurisdiction by PGT & Associates.

Direct tax litigation manual on automated CPC adjustments: Responding to Section 143(1)(a) intimations for Form 3CD disallowance discrepancies, submitting online rejoinders on e-filing portal within 30 days, and filing Section 154 rectification requests by PGT & Associates.

Comprehensive direct tax compliance manual on Section 194S: 1% TDS withholding on crypto and NFT transfers, ₹50,000 vs ₹10,000 thresholds for specified persons, Form 26QF challan filing, exchange vs P2P liability, and Section 271C penalty defense by PGT & Associates.

Direct tax controversy masterclass on Section 68: First proviso share capital/premium scrutiny, 'source of source' requirements, Section 115BBE 78% punitive tax, accommodation entry defenses, and the judicial Triple Test by PGT & Associates.

Comprehensive direct tax and audit guide on Section 43B(h): MSMED Act Section 15 payment windows (15 days vs 45 days), wholesale/retail trader exemptions, Form 3CD Clause 22 reporting, compound penal interest disallowance, and supplier master cleanup by PGT & Associates.

Procedural defense manual against reassessment notices: Section 148A enquiry, Finance Act 2024 revised limitation windows, ₹50 Lakh escaped income threshold, and writ remedies by PGT & Associates.

Direct tax litigation advisory on the revised Section 148 reassessment regime: CBDT Risk Management System criteria, Section 148A show-cause procedure, Rs. 50 Lakh asset threshold, and limitation defenses by PGT & Associates.

Comprehensive compliance guide on Section 194R withholding tax on business perquisites: Valuation methodologies, Rs. 20,000 threshold verification, dealer incentives, and Form 3CD reporting by PGT & Associates.