Monthly Archives: January 2026

IMPORTANT INCOME TAX CASE LAWS 16.01.2026 Relevant Act Section Case Law Title Brief Summary Citation Income-tax Act, 1961 Section 14A / Rule 8D Asia Investments (P.) Ltd. v. ACIT [Nexus for Disallowance] Disallowance under Section 14A (Rule 8D) is restricted to expenditure having a proximate nexus with exempt income. Mechanical application of Rule 8D without… Read More »

Unclaimed TDS credit allowed at effect-giving stage where corresponding income was offered to tax   Issue Whether the Assessing Officer was justified in denying TDS credit of Rs. 73.24 lakhs discovered in an updated Form 26AS at the order-giving-effect stage, solely because it was not claimed in the filed returns, despite the corresponding income being… Read More »

Benefit of New Tax Regime for AY 2023-24 allowed despite one-day delay in previous Form 10-IE   Issue Whether the assessee can be denied the benefit of the New Tax Regime under Section 115BAC for Assessment Year 2023-24 solely because the Form 10-IE filed for the preceding year (AY 2022-23) was delayed by one day,… Read More »

Reassessment invalid if sanction obtained after initial rejection; uncorroborated loose sheets cannot trigger reopening   Issue Whether the reassessment proceedings under Sections 147/148 are valid if the Competent Authority initially rejected the sanction proposal but approved it upon re-presentation, and whether loose sheets found on a third party constitute sufficient material to form a “reason… Read More »

Alleged on-money addition deleted due to lack of evidence; deemed rent on unsold units sustained   Issue On-Money (Section 69A): Whether the Assessing Officer (AO) was justified in making additions for alleged “on-money” receipts based solely on loose slips found during a search on a third party and estimated cost differences, without corroborative evidence or… Read More »

Recording Satisfaction u/s 14A Mandatory; Business Expenses for Strategic Investments Allowed   Issue Jurisdictional Validity: Whether the Assessing Officer (AO) can invoke Rule 8D to compute disallowance under Section 14A without recording explicit satisfaction regarding the incorrectness of the assessee’s suo motu claim. Duplication of Disallowance: Whether ad hoc allocation of administrative expenses as “direct… Read More »

Assessment quashed as Section 148 notice issued by JAO violates mandatory Faceless Assessment Scheme   Issue Whether a notice issued under Section 148 by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO) is valid after the notification of the ‘e-Assessment of Income Escaping Assessment Scheme, 2022’, and consequently, whether the assessment… Read More »