IMPORTANT INCOME TAX CASE LAWS 12.01.2026 Relevant Act Section Case Law Title Brief Summary Citation Income-tax Act, 1961 Section 32 / 37(1) Spectris Technologies (P.) Ltd. v. ITO [Non-Compete Fee] Following the landmark SC ruling in Sharp Business System, the AO was directed to treat Non-Compete Fees as Revenue Expenditure (deductible u/s 37) rather than… Read More »
Land Levelling Costs Allowed for Section 54B Deduction; Revenue’s Lower FMV Estimate for 1981 Upheld Issue Section 54B (Agricultural Land Deduction): Can expenses incurred on levelling and fencing of newly purchased agricultural land be included in the “cost of the new asset” for claiming deduction under Section 54B? Section 48 (Cost of Acquisition –… Read More »
Double Deduction of Upfront Fee Denied; Corporate Guarantees and SBLC Treated as International Transactions Issue Upfront Fee (Double Deduction): Can an assessee claim amortization (1/5th) of an upfront fee paid for debentures in the current year if the Tribunal has already allowed the entire amount as a deduction in a previous assessment year? Corporate… Read More »
Segmental Benchmarking for TP Upheld; Non-Compete Fee Treated as Revenue Expenditure Issue Transfer Pricing (Segmental Analysis): Whether a company engaged in both trading (equipment supply) and services (installation/after-sales) should benchmark these activities separately using segmental analysis, or if they can be aggregated. Non-Compete Fee (Nature of Expense): Whether Non-Compete Fees (NCF) paid by the… Read More »