Dear Sir/Madam,

We seek your professional opinion regarding the applicability of TDS under Section 195 of the Income-tax Act, 1961, on payments made to Adobe Systems Software Ireland Limited towards Adobe subscription charges.

1- Background of the transaction:
Payments have been made for Adobe software subscriptions.
The payments were routed through credit card / online payment gateway.
Adobe Systems Software Ireland Limited has provided the following documents:
No Permanent Establishment (PE) declaration in India
Form 10F
2- Clarifications received from Adobe:
Payments made via credit card fall under the proviso to Section 194Q and relevant CBDT clarifications.
TDS obligation does not apply where:
a) Payment is made through credit cards, debit cards, or similar electronic modes; and
b) The bank / payment gateway acts as an intermediary for the transaction.
The responsibility for tax collection does not shift to Adobe in such cases.

3- Our queries for your expert advice:
Whether TDS is applicable under Section 195 on the above payments made to Adobe Systems Software Ireland Limited?
If TDS is applicable, please advise:
The nature of income (royalty / FTS / other),
The applicable rate of TDS, and
Whether DTAA provisions between India–Ireland can be applied in this case.
Whether payment through a credit card/payment gateway alters the TDS obligation under Section 195.

Your guidance on the above will help us ensure correct tax compliance.

Thanking you in advance.
Warm regards,

My income tax returns are already processed for FY 24-25 and I have got TCS credit in form 26 AS after processing returns. Can I claim FY 24-25 TCs refund in FY 25-26

Respected Sir/Madam,
We have only 15G/15H challans in this quarter and no other TDS payments, we have already submiitted form 15G/15H on 15th jan 2026 but while filing TDS Return it ask for challan payments which we don`t have

How to file this return

Please reply

Regards

Tribhuvan

for FY 24-25 AY 25-26 The assessee is in Goa and while filing his return of income everything was shown between him and spouse at 50%.
only prepaid taxes were different and accordingly refund asked was for different amounts
There was business loss to be set off against income from other sources.
In wife case As per intimation received u/s 143(1) business loss was adjusted against income from other sources
However in husband case as per intimation u/s 143(1) business loss is not adjusted against income from other sources resulting in demand
rectification request was filed u/s 154 but in the order again the benefit of business loss is not given and demand is confirmed
My question is
what can be done in above case so that business loss is adjusted against other income like already given in wife case ?

Dear Sir
Is the gratuity and leave encashment received on death of employee in private sector is 100% exempt or upto the specified limits. For leave encashment, is still the letter no. 573 of 1965 still applicable.

Dear Professional friends very good morning.
my client who is now in UAE N Visited july 30th 2025 india and returned to dubai by august 21st 2025 now willing to sale a property in bangalore apprx 1.5cr, which the same bought for apprx 1cr as on 2022 coctber. so kindly share me tds applicability for NRI and other capital gain provisions In brief and value of capital gain in a nominal values. which section 194 or 195 of incometax act will be applicable for tds. kindly support us they are in dubai and not known provisions of these tax and statutory implications. thank you in advance for your utmost support and time spent for our querry.

Few months back I book profit in international equity mutual fund. As it was invested around 14 months so it is STCG. Apart from this I sell some indian equity mutual fund with loss within one year which cause loss in short term.
As per my research gain on international fund redemption is going to be added in taxable income same as debt funds and this gain is not under capital gain consideration (correct me if wrong).
My query is can I balance my indian equity MF loss against international MF gain?
Or as this international MF gain is going to be part of my income and above indian short term loss need to get balance with my other equity LTCG and equity STCG?
Share your insight please.

Immovable property gift deed done by daughter to mother. circle rate value of plot 8.4 lakh. Non of them currently files ITR. Can there be any problem if itr is not filled for this deed kindly tell

Whether ITAT can allow exemption to an educational institution u/s 10(23C)(iiiad), if AO and CIT(A) had disallowed exemption u/s 11 and also did not allowed exemption u/s 10(23C)(iiiad), being not claimed in ITR ?

Also share the relevant case laws to be cited while appealing to ITAT.

TIA

One of client enterd in the purchase of a residential unit, say in January 2026 for under construction. And in February 2026, he sold commercial property.

My query is whether under construction property FIRST and then sell the commercial property. Ccan he get deduction u/s 54 F in Income Tax?