Daily Archives: February 18, 2026

IMPORTANT INCOME TAX CASE LAWS 18.02.2026 Relevant Section Case Law Title Core Ruling / Summary Citation Section 2(47) Zarir Rustom Joshi v. ITO [JDA Transfer Date] If a development agreement was registered and full consideration was received in 2000, the transfer is complete. LTCG cannot be re-computed on the final sale deed in 2008 by… Read More »

Supreme Court Allows Revenue to Represent Clarification on Local vs. Faceless Assessment Jurisdiction in Reopening Cases 1. The Core Dispute: JAO vs. Faceless Assessing Officer (FAO) The High Court had originally ruled in favor of the assessee, quashing reassessment notices issued under Section 148. The primary reason was that the Jurisdictional Assessing Officer (JAO)—the local… Read More »

Invalidation of Assessment Proceedings Due to Service of Section 143(2) Notice Beyond Statutory Limitation Period 1. The Core Dispute: Time-Barred Scrutiny Notice The primary issue in this case was whether the Assessing Officer (AO) complied with the strict statutory timeline for serving a scrutiny notice under Section 143(2). For the relevant assessment year, the law… Read More »

Deletion of Addition under Section 56(2)(x) where Variation Between Purchase Price and Stamp Duty Value is within 10% Safe Harbor Limit 1. The Core Dispute: Stamp Duty Valuation Mismatch The assessee, a partnership firm in the real estate development business, purchased land with structures. After an initial conveyance deed, a supplementary deed was executed, fixing… Read More »

Scholarship for Foreign Studies & Condonation of Delay in Section 12AB Registration 1. Core Dispute: Scholarship as “Application Outside India” The Assessing Officer (AO) rejected the trust’s application for registration under Section 12AB on the grounds that the trust violated Section 11(1)(c). The violation was alleged because the trust provided a ₹2 lakh scholarship for… Read More »

Duty of Appellate Authorities to Grant Legitimate Relief Even if Not Claimed in Original Income Tax Return 1. The Core Dispute: Technical Error vs. Substantive Exemption The assessee, an NGO registered under Section 12A, inadvertently disclosed its interest income from FDRs and bank deposits under the head ‘Income from Other Sources’ instead of claiming it… Read More »

Conversion of Share Warrants into Equity Shares Held Not to Constitute a Taxable Transfer 1. The Core Dispute: Conversion vs. Sale The assessee held share warrants and eventually converted them into equity shares by paying the remaining balance of the exercise price. The Assessing Officer (AO) viewed this event as a taxable “transfer” of rights.… Read More »

Invalidation of Reassessment Where Transfer of Land Was Completed via Development Agreement in a Prior Year 1. The Core Dispute: 2000 (Agreement) vs. 2008 (Sale Deed) The Assessing Officer (AO) reopened the assessment for AY 2009-10 after finding a registered sale deed dated April 2008. The AO argued that the “transfer” of land took place… Read More »