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Orange Bulletin : Ordinance : Economic Turnaround by sweeping reforms; DVO reference vis-a-vis Sec. 56(2)(vii)(b)(ii); Interest on delayed payment of VRS and more!!

 

Issue No. 186th / September 24th, 2019  

 
Expert Column:
 
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Recently the Government announced certain major tax concessions in an attempt to revive the Indian economy. Authors Vinay Deshmane (Director, TRS, BDO India LLP) & Dhwanil Shah, (Assistant Manager) discuss the amendments brought about by way of an ordinance viz. the Taxation Laws (Amendment) Ordinance 2019. The authors elaborate on the salient features of the Concessional Tax Regime (CTR), for existing and new manufacturing companies along with the relevant conditions to avail the same, rollback of enhanced surcharge and grandfathering Buyback Tax in case of listed shares. Comparing the CTR with the existing tax rates, the authors opine that “Reduction in tax rates will make India an attractive jurisdiction for making investments”. Thereafter the authors bring out how the CTR would have an impact on the preference of choice of entity from a LLP form to a corporate form. Speaking of the unavailability of MAT Credit to entities opting for the CTR, the authors suggest that “ since no timeline has been prescribed for exercising the option under section 115BAA, a domestic company having credit of MAT, may opt for CTR after utilising the said credit against the regular tax payable.” They further bring out that while the domestic Transfer Pricing provisions shall be applicable to new manufacturing companies opting for CTR, it is not applicable to other existing companies opting for the same. The authors sign off listing the benefits of the regime such as boost to foreign investments, higher profits being distributed to the stakeholders, stimulus to ‘Make in India’ initiative, etc.

Click here to read the article titled “Economic Turnaround by sweeping reforms: Taxation Aspects and Issues”
 
Key Takeaways from Handpicked rulings
 
1. [TS-7656-ITAT-2019(Kolkata)-O] :DVO reference vis-a-vis Sec. 56(2)(vii)(b)(ii) : DVO reference mandatory before adopting stamp duty valuation for purpose of Sec. 56(2)(vii)(b)(ii) - ITAT rules in favour of assessee; Holds that AO is duty bound to make a reference to the DVO before adopting the value of assets determined by the Stamp Valuation Authority for the purpose of bring to tax u/s. 56(2)(vii)(b)(ii), the difference between the market value of the property purchased by assessee (as determined by the Stamp Valuation Authority) and the actual purchase price; Notes that the addition made by the AO was confirmed by the CIT(A) holding that in the absence of any objection raised by the assessee to the valuation determined by the Stamp Valuation Authority, the AO was not required to make any reference to the Valuation Officer; Relies on Calcutta HC ruling in case of Sudhir Kumar Agarwal [TS-5281-HC-2014(Calcutta)-O]
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
2. [TS-7770-ITAT-2019(Pune)-O] : Sale of sugar at concessional rates, Excessive sugarcane price paid : Sale price of sugar only to extent it is below cost price is ‘appropriation of profit’, taxable in hands of assessee; Directs to bifurcate sugarcane purchase price and tax only to extent of component of distribution of profit embedded in the price paid under clause 5A Sugar Cane (Control) Order : ITAT rules on taxability of deduction for payment of excessive price for purchase of sugarcane to suppliers and sale of sugar at concessional rates to members / shareholders by assesses who are engaged in the business of manufacturing of white sugar;
 
Click here to read the Ruling Copy.
 
3. [TS-5800-HC-2019(Delhi)-O] : Expenditure on Director’s daughter’s higher education : Funding the education expenses of the daughter of a director, when the underlying facts revealed that the expenditure was purely personal in nature and not intended for the purpose of the business of the assessee company, could not be allowed to be claimed as a deduction u/s. 37 - HC disallows expenditure on higher education of daughter of the director of the assessee-company; Observes that the agreement between the company and the director’s daughter defied logic, whereunder the company undertook payment of over Rs. 70 lakhs for her higher education and sought a commitment of only 1 year’s employment from the date of completion of her education;
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
4. [TS-7649-ITAT-2019(Bangalore)-O] : Allowability of interest on delayed payment of VRS u/s. 35DDA : Deduction over 5 years u/s. 35DDA applicable to interest on delayed payment of VRS also - ITAT dismisses assessee’s appeal against AO’s allowance of only 1/5th amount of interest incurred and disallowance of the remaining amount for AY 2009-10; Holds that “ section 35DDA is applicable to any payment in connection with VRS payment to employees and since, the interest expenditure in dispute in the present case is in connection with VRS payment of employees, this amount is also hit by the provisions of section 35DDA of the IT Act and therefore, in the present year, only 1/5th is allowable as already allowed by the AO”;
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.

About Orange :

Taxsutra & LexisNexis together present the game-changer product - 'Orange', that for the first time ever, combines the best of both worlds - Repository of over 104,500+ income-tax rulings as reported in 7 journals viz., ITR, CTR, Taxman, DTR, ITD & ITR-Trib. which also includes recent ruling handpicked by Orange Editorial Team  & the iconic tax commentary - Chaturvedi & Pithisaria (C&P), covering over 80,000 judicial decisions and meticulously arranged under 25,000 headings & sub-headings.

Orange - What Makes it Special! 

• Integration of database and commentary to give the users a seamless experience

• C&P commentary available alongwith the relevant common judgment

• Expert views in C&P commentary right there

• Common cases in C&P Commentary available at a click of button.

• Updated with latest cases reported in ITR , CTR and other leading journals

• Powerful search engine that shall get you the desired results at click of a button

• Search algorithm developed based on cutting-edge technology and deep tax domain experience

• Various filters available for both Orange and C&P for refining the search results viz., court level, location, case number, citation and others

• Unique 'Bulls Eye' Search Tool  with options like “exact words”, “any of these” & “none of these” to further refine search results.

• Option to search within C&P Commentary – subject & section index available

• Option to search within the judgment copy

• And lots more…

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Orange Bulletin : Relevance of ‘disposal of objections’ law u/s. 147 to Benami Act, Business expenses during liquidation, CBDT Updates and more…!

 

  Issue No. 184th / August 26th, 2019

 

Key Takeaways from Handpicked rulings
 

1. [TS-5607-HC-2019(GUJARAT)-O] : Relevance of ‘disposal of objections’ law u/s. 147 to Benami Act : Proviso of sec. 24(2) of the Benami Act and 147 of IT Act are completely different, AO not bound to dispose by passing a separate speaking order to the objections raised - HC dismisses assessee's petition, holds holds claim of the assessee to pass a separate order dealing with the objections as not supported by any provision of law; Examines sec.24, 25 and 26 and notes that “Section 24 of the Benami Act and the subsequent provisions are for the purpose of coming to conclusion as to whether the property in question is to be treated as benami property whereas operation of Section 147 of the Income Tax Act and the subsequent provisions, viz. Sections 148 to 153 would be operating while the process for assessing or reassessing of the income is undertaken by the concerned officer”... 

Click here to read the Ruling Copy.
 
2. [TS-6943-ITAT-2019(BANGALORE)-O] : Business expenses during liquidation : Running expenses incurred during liquidation of a company, allowable as a business expenditure - Bangalore ITAT allows assessee’s appeal for AY 2015-16, allows expenses (such as professional fees, audit fees etc.) as a deduction though the business of the assessee has come to a halt, observes that though the business came to a halt in the year 2010, the assessee was still liquidating its assets until the previous year; States that “All these expenses had to be incurred since the assessee was a company and it was required to maintain its legal status till the assets of the company are liquidated”, follows Karnataka HC judgment in Lawrence D’souza...
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
3. [TS-6942-ITAT-2019(VISAKHAPATNAM)-O] : Completion Certificate vis-a-vis deduction u/s. 80-IB(10) : Completion Certificate mandatory requirement for claiming deduction u/s. 80-IB(10) - ITAT upholds CIT(A) order denying deduction u/s. 80-IB(10) absent completion certificate, evidence to establish that the project was completed in all respects as per the plan for AY 2007-08; Holds furnishing of completion certificate mandatory for purpose of claiming dedcution u/s. 80IB(10); Assessee’s case was reopened upon noting that though the assessee had claimed deduction u/sec. 80IB(10) during the pendency of the project, subsequently the assessee has not filed returns of income, thus, viewed that the assessee has not completed the project...
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
4. [TS-6944-ITAT-2019(BANGALORE)-O] : Souharda co-operatives  : Souharda co-operatives also a form of co-operative societies, eligible for deduction u/s. 80P(2)(a)(i) - ITAT rules in favour of assessee, allows deduction u/s. 80P(2)(a)(i) to a  ‘souharda co-operative’; Refers to the definition of co-operative society and observes that any co-operative society registered under any other law of any State for registration of co-operative society is also regarded as co-operative society under the Act, states that ‘Souhardas’ also operate on the principle of co-operation and infers that “Cooperative Societies and Co-operatives are all founded on the principle of cooperation.”...
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
5.  [TS-6942-ITAT-2019(MUMBAI)-O] : Royalty Payments : Payments made for obtaining access to the information, not resulting in acquisition of any capital asset, are revenue in nature - ITAT allows assessee’s appeal, holds royalty expenditure to be revenue in nature and thus, allowable u/s. 37(1); Notes that the assessee made the payments only for obtaining access to the information, which does not become the property of the assessee as there is no purchase of technical know how and the title and ownership has not been transferred to the assessee, follows SC decision in Ciba of India; Observes that “under the agreement, the assessee did not become entitled exclusively, even for the period of agreement, to the patents and trademarks of the licensor, it had merely assessed to the technical knowledge and experience, which the licensor commanded and was a mere licence for a limited period of the technical knowledge with the right to use the patent and trademarks.”...
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
CBDT Updates:
 
https://ci5.googleusercontent.com/proxy/cICQffTpQFTthn9CGLXCqLTzFer_Z4qyAIy5uUxuIWkIFdHxPkHeZ2egMZDwjgyfoEtqCU8vTxYfAyNrQYwGDp9hWUY=s0-d-e1-ft#https://ymlp8.com/imgz/f33j_unnamed--10.jpg
1. CBDT clarifies on eligibility of small startups to avail Sec. 80-IAC tax holiday
2. CBDT directs quoting of 'DIN' in all Departmental communication from October 1st
3. MOF : Government withdraws enhanced surcharge on tax payable on transfer of certain assets
4. CBDT rebuts incorrect reports about Income Tax notices to Durga Puja Committees
5. Income tax department unearths Rs 700 crore undisclosed income in Tamil Nadu
6. CBDT simplifies the process of assessment in respect of Startups
7. CBDT further enhances monetary limits for filing Departmental appeals before ITAT / Courts
 

Click here to read more latest news

 

About Orange :

Taxsutra & LexisNexis together present the game-changer product - 'Orange', that for the first time ever, combines the best of both worlds - Repository of over 103,500+ income-tax rulings as reported in 7 journals viz., ITR, CTR, Taxman, DTR, ITD, ITR-Trib. & SOT, which also includes recent ruling handpicked by Orange Editorial Team  & the iconic tax commentary - Chaturvedi & Pithisaria (C&P), covering over 80,000 judicial decisions and meticulously arranged under 25,000 headings & sub-headings.

Orange - What Makes it Special! 

• Integration of database and commentary to give the users a seamless experience

• C&P commentary available alongwith the relevant common judgment

• Expert views in C&P commentary right there

• Common cases in C&P Commentary available at a click of button.

• Updated with latest cases reported in ITR , CTR and other leading journals

• Powerful search engine that shall get you the desired results at click of a button

• Search algorithm developed based on cutting-edge technology and deep tax domain experience

• Various filters available for both Orange and C&P for refining the search results viz., court level, location, case number, citation and others

• Unique 'Bulls Eye' Search Tool  with options like “exact words”, “any of these” & “none of these” to further refine search results.

• Option to search within C&P Commentary – subject & section index available

• Option to search within the judgment copy

• And lots more…

 

 

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Orange Bulletin : An appraisal of recent SC ruling in NRA Iron; Delay in filing application for condonation of delay in filing ROI, Appeal dismissal by ITAT for want of prosecution and more…!

 

 Issue No. 182nd / April 23rd, 2019
 
Expert Column:
 
Critical appraisal of the recent SC ruling in NRA Iron and its impact
Recently, the Supreme Court, in an ex-parte decision in the case of NRA Iron, ruled upon the applicability of Sec. 68 in the scenario of issue of shares at a high premium while reversing all the lower Courts decisions. The Apex Court held that if upon investigation, the AO comes to a conclusion that the identity, genuineness and creditworthiness of the investors is doubtful, then the onus of the assessee does not stand discharged by merely supplying the details pertaining to the identity, genuineness and creditworthiness of the investors. The author Mr. Prakash Sinha, Chartered Accountant, discusses this landmark ruling wherein SC has elucidated that the term “any sum found credited in the books” is widely worded and includes investments made by share capital or share premium. Regarding SC’s observation that creditworthiness of certain companies were not established, the author opines that “taxable income is not a correct parameter to check the credit worthiness of the creditor as the investor may have funds which is available in Balance sheet and not in Profit-loss accounts”. The author further opines that “Supreme Court should have tested the section 68 requirements on case to case basis (each investor wise) rather than painting all with the same color”. Speaking of the impact of the SC decision on subsequent assessments and decisions, the author discusses a recent and subsequent ruling of Kolkata ITAT in the case of Baba Bhoothnath wherein it has been held that where the entire detail of the source of source were furnished by the respective share subscribers and the directors themselves appeared before AO and explained all the transactions with evidence and AO has nothing adverse, then the NRA Iron ruling is factually distinguishable and cannot be applied.
Click here to read the article titled “Critical appraisal of the recent SC ruling in NRA Iron and its impact
 
Key Takeaways from Handpicked rulings

1. [TS-5140-HC-2019(BOMBAY)-O] : Delay in filing application before CBDT for condonation of delay in filing ROI : HC dismisses assessee’s writ petition against CBDT’s order rejecting its plea for condonation of delay in filing the return of income for AY 2008-09; Observes that, quite apart from delay in filing the return, the assessee also had to demonstrate why the application for condonation of delay could not be filed for as long as six years, which it failed to demonstrate satisfactorily; Hence, opines that “the petitioner has not been prompt in pursuing the remedies on the ground of limitation and latches”;

Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.

2. [TS-5141-HC-2019(MADRAS)-O] : Appeal dismissal by ITAT for want of prosecution : A legal and binding responsibility lies upon the Tribunal to decide an appeal on merits irrespective of the appearance of the assessee or his representative before it - HC allows assessee’s appeal, sets aside ITAT order and directs ITAT to decide the matter afresh on merits in accordance with law; Holds that ITAT erred in dismissing assessee’s appeal for want of prosecution without touching upon merits of the case and then further in dismissing the Miscellaneous Petition filed for recalling the ex parte order; Considering the enabling powers in the words 'as it thinks fit' employed in Section 254 read with Rule 24 of the ITAT Rules, explains that “Even if the assessee could not appear, the Tribunal could have decided the appeal only on merits, ex parte, after hearing the Revenue Side but, the dismissal of the appeal for want of prosecution is not only illegal but also entails further litigation”

Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
3. [TS-5798-ITAT-2019(MUMBAI)-O] : Reassessment / Issue of shares at premium : Mere issuing of shares on premium, cannot be a reason to believe for re-opening of assessment in absence of adverse allegation more particularly when the receipt is on capital account - ITAT holds reassessment for AY 2009-10 as bad in law; Noting that assessee had submitted all the relevant details which were examined by the AO in the original assessment proceedings, states that the reassessment is “nothing but a change of opinion on the same set of facts and cannot be resorted to u/s 147”; Also notes that the AO has recorded and proceeded on factually incorrect facts such as premium amount, no of shares etc. and thus, holds the reassessment proceeding as illegal and liable to be quashed; Follows precedents;
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
4. [TS-5109-HC-2019(MADHYA PRADESH)-O] : Mere non-filing of Income Tax Return does not automatically dislodge the source of income of a person - HC in a criminal case under Negotiable Instruments Act while dealing with a dispute on a dishonoured cheque, examines the relevance of Income Tax Returns for establishing source of income of a person alleging to have granted a loan, holds that mere non-filing of Income Tax Return by itself would not mean that the person claiming to have granted a loan had no source of income; HC clarifies that whether there was any loan transaction between the parties or not and whether there was any legally recoverable debt or not, is the subject-matter which can be ascertained in the light of entire case led by the parties;
Click here to read the Ruling Copy
5. [TS-5802-ITAT-2019(PUNE)-O] : Interest on NPAs, Depreciation on Investment of a Co-operative Bank : Interest on NPAs of a cooperative bank not chargeable to tax; Depreciation on investment is allowable as a deduction- ITAT dismisses Revenue’s appeal, observes that prudential norms issued by RBI are applicable to Co-operative Banks and that interest on sticky advances cannot be said to be accrued and are hence, not taxable, follows decisions of Bombay and Delhi HCs in the cases of  Deogiri Nagari Sahakari Bank and Shri Mahila Seva Sahakari Bank; Further, allows depreciation on investment, follows Bombay HC decision in HDFC Bank wherein it was held that though they have been shown as investments in the balance sheet as per RBI Guidelines, they are stock in trade and hence, if the market value is less than the cost price, in law, assessee is entitled to deductions and it cannot be denied by the authorities under the pretext that it is shown as investment in the balance-sheet
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 

About Orange :

Taxsutra & LexisNexis together present the game-changer product - 'Orange', that for the first time ever, combines the best of both worlds - Repository of over 100,500+ income-tax rulings as reported in 7 journals viz., ITR, CTR, Taxman, DTR, ITD, ITR-Trib. & SOT, which also includes recent ruling handpicked by Orange Editorial Team  & the iconic tax commentary - Chaturvedi & Pithisaria (C&P), covering over 80,000 judicial decisions and meticulously arranged under 25,000 headings & sub-headings.

Orange - What Makes it Special! 

• Integration of database and commentary to give the users a seamless experience

• C&P commentary available alongwith the relevant common judgment

• Expert views in C&P commentary right there

• Common cases in C&P Commentary available at a click of button.

• Updated with latest cases reported in ITR , CTR and other leading journals

• Powerful search engine that shall get you the desired results at click of a button

• Search algorithm developed based on cutting-edge technology and deep tax domain experience

• Various filters available for both Orange and C&P for refining the search results viz., court level, location, case number, citation and others

• Unique 'Bulls Eye' Search Tool  with options like “exact words”, “any of these” & “none of these” to further refine search results.

• Option to search within C&P Commentary – subject & section index available

• Option to search within the judgment copy

• And lots more…

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Orange Annual Digest - A Compilation of 100+ important rulings of year 2018-19
 
 Issue No. 181 / April 5th, 2019

 

Orange Annual Digest - A Compilation of 100+ important rulings of year 2018-19
 
We at Orange from time to time, bring to our readers, latest and important rulings handpicked from our repository of over 100,500+ rulings through our weekly newsletters. As we mark the close of the financial year 2018-19, we present a compilation of 100+ important rulings reported on Orange during the year. We trust the compilation will serve as a handy and useful reference to all our readers.

Click here to read and download Orange Annual Digest 2018

 

About Orange :

Taxsutra & LexisNexis together present the game-changer product - 'Orange', that for the first time ever, combines the best of both worlds - Repository of over 100,500+ income-tax rulings as reported in 7 journals viz., ITR, CTR, Taxman, DTR, ITD, ITR-Trib. & SOT, which also includes recent ruling handpicked by Orange Editorial Team  & the iconic tax commentary - Chaturvedi & Pithisaria (C&P), covering over 80,000 judicial decisions and meticulously arranged under 25,000 headings & sub-headings.

Orange - What Makes it Special! 

• Integration of database and commentary to give the users a seamless experience

• C&P commentary available alongwith the relevant common judgment

• Expert views in C&P commentary right there

• Common cases in C&P Commentary available at a click of button.

• Updated with latest cases reported in ITR , CTR and other leading journals

• Powerful search engine that shall get you the desired results at click of a button

• Search algorithm developed based on cutting-edge technology and deep tax domain experience

• Various filters available for both Orange and C&P for refining the search results viz., court level, location, case number, citation and others

• Unique 'Bulls Eye' Search Tool  with options like “exact words”, “any of these” & “none of these” to further refine search results.

• Option to search within C&P Commentary – subject & section index available

• Option to search within the judgment copy

• And lots more…

 

 

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Orange Bulletin : CIT(A)’s powers to adjudicate on issue(s) not dealt with by AO; Referral-fees paid by Indian-Branch to overseas-branch; CBDT updates and more…!

 

Issue No. 180 / March 28th, 2019

Key Takeaways from Handpicked rulings
 
1. [TS-5699-ITAT-2019(DELHI)-O] : CIT(A)’s powers to adjudicate on issue(s) not dealt with by AO : CIT(A) does not have jurisdiction to make an addition on an issue which was never considered by the AO - ITAT grant relief to assessee, deletes addition made by CIT(A) u/s 56(2)(viib) on account of share premium; Explains that although the powers of the CIT(A) are co-terminus with that of the powers of the AO, yet, he has jurisdiction only on those items which have been considered by the AO irrespective of the fact whether the issue is subject matter of appeal or not; States that “In case it is accepted that the ld.CIT(A) has power to consider an issue which was not considered by the Assessing Officer, then, the provisions of section 263 or 147 will become otiose”;
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
2. [TS-5692-ITAT-2019(MUMBAI)-O] : Taxability of clients Referral-fees paid to overseas branch, Interest paid by India branch to overseas HO : Referral-fees paid by Indian-Branch of Credit Suisse to Dubai-Branch for referring clients not FTS; Interest paid by Indian-branch to overseas head-office is neither deductible in the hands of Indian Branch nor chargeable to tax in the hands of head office - ITAT rules in favour of assessee; Relies on coordinate bench decision in assessee’s own case for AY 2011-12 [TS-5573-ITAT-2018(MUMBAI)-O] and Special Bench decision in Sumitomo [TS-187-ITAT-2012(MUMBAI)-O]
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
3. [TS-5701-ITAT-2019(MUMBAI)-O] : Sec.54-Use of sale proceeds for investment in new house property : Sec. 54 does not require that the sale proceeds from transfer of original capital asset must be used for meeting cost of new asset - ITAT allows assessee’s appeal appeal for AY 2005-06, allows deduction u/s. 54 to assessee rejecting AO’s reason for denying that the investment made towards purchase of new flats was not out of assessee’s own funds; Notes that assessee has made investment in a new property within the period stipulated u/s. 54(1) and states that “There being no pre–condition under section 54(1) of the Act providing for investment of the long term capital gain in purchase of new house for claiming deduction under section 54 of the Act, the departmental authorities cannot import such restriction/condition to the statutory provision”;
 
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
4. [TS-5026-SC-2019-O] : Remuneration to Directors u/s. 40A(2)(b); Disallowance u/s. 14A : AO having accepted remuneration paid to directors in preceding year, cannot make disallowance u/s. 40A(2)(b) by comparing the payments made in earlier years; No deduction u/s. 14A when assessee is having enough surplus funds - SC dismisses Revenue’s SLP against HC order deleting addition u/s. 40A(2)(b) and Sec. 14A r/w Rule 8D
Click here to read the Ruling Copy and Chaturvedi & Pithisaria Commentary on similar issue.
 
CBDT Updates:
 
1. Income tax exemption for gratuity enhanced Up to Rs. 20 lakhs
 
2. Income Tax Department continues to hit at terror financing activities in J&K Region
 
Click here to read more latest news
 

About Orange :

Taxsutra & LexisNexis together present the game-changer product - 'Orange', that for the first time ever, combines the best of both worlds - Repository of over 100,100+ income-tax rulings as reported in 7 journals viz., ITR, CTR, Taxman, DTR, ITD, ITR-Trib. & SOT, which also includes recent ruling handpicked by Orange Editorial Team  & the iconic tax commentary - Chaturvedi & Pithisaria (C&P), covering over 80,000 judicial decisions and meticulously arranged under 25,000 headings & sub-headings.

Orange - What Makes it Special! 

• Integration of database and commentary to give the users a seamless experience

• C&P commentary available alongwith the relevant common judgment

• Expert views in C&P commentary right there

• Common cases in C&P Commentary available at a click of button.

• Updated with latest cases reported in ITR , CTR and other leading journals

• Powerful search engine that shall get you the desired results at click of a button

• Search algorithm developed based on cutting-edge technology and deep tax domain experience

• Various filters available for both Orange and C&P for refining the search results viz., court level, location, case number, citation and others

• Unique 'Bulls Eye' Search Tool  with options like “exact words”, “any of these” & “none of these” to further refine search results.

• Option to search within C&P Commentary – subject & section index available

• Option to search within the judgment copy

• And lots more…

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