ITC Denial Quashed as Section 16(5) Overrides Original Limitation Period for FY 2017-18 to 2020-21 1. The Core Dispute: Statutory Deadlines vs. Retrospective Relief The petitioner’s Input Tax Credit (ITC) claims for late 2019 and early 2020 were originally rejected. The tax authorities argued that the returns (filed in December 2020 and November 2021) were… Read More »
IMPORTANT INCOME TAX CASE LAWS 19.02.2026 Section Case Law Title Core Ruling & Strategic Summary Citation S. 148 / 151A Vibhavari B. Bhatt v. ITO [Landmark – Faceless Mandate] Reassessment notices issued after 29-3-2022 by a Jurisdictional AO (manual) instead of the Faceless AO are void. High Court rulings (e.g., Hexaware Tech) are binding on… Read More »
TRO Not Empowered to Declare Third-Party Mortgage Void-Ab-Initio but Retains Right to Sell Attached Property Post-Rule 2 Notice 1. Scope of Section 281(1): Pendency of Proceedings Section 281(1) acts as a protective shield for the Revenue, declaring certain transfers void if they occur during the pendency of any proceeding or after completion but before the… Read More »
NBFC Entitled to Section 37(1) Deduction for Mark-to-Market Losses on NIFTY-Linked Debentures Under Mercantile System 1. The Core Dispute: Realized Loss vs. Contingent Liability The assessee, an NBFC, issued specialized debt instruments known as Benchmark Linked Debentures (BLDs). These were principal-protected, meaning the original investment was safe, but the “coupon” (interest) was contingent upon the… Read More »
Development Authorities Entitled to Section 11 Exemption Provided Commercial Receipts Stay Within the 20% Threshold 1. The Core Dispute: Charitable Purpose vs. Commercial Activity The assessee, a statutory Development Authority (similar to DDA, AUDA, or GIDC), claimed exemption under Section 11. The Assessing Officer (AO) rejected the claim, citing the provisos to Section 2(15). AO’s… Read More »
Revenue Prevails as Trader Fails to Prove Income Source Within Specified Tribal Area Despite ST Status 1. The Core Dispute: Exemption vs. Unexplained Money The assessee, a trader, failed to file his Income Tax Returns (ITR) for AY 2013-14 and 2014-15. Based on data from the Insight Portal, the Income Tax Department detected significant cash… Read More »
Quashing of Bogus Purchase Additions Based on GST Records and Allowability of Compensatory Interest on TDS 1. Bogus Purchases vs. GST Compliance (Section 69C) Title: [GST Registration and Filing Establish Authenticity of Purchases Despite Supplier’s Non-Response to IT Notices] The Assessing Officer (AO) treated purchases from a specific supplier as “bogus” because the supplier failed… Read More »
Accrued Interest on NPAs Taxable Where Assessee Extends Fresh Credit, Overriding RBI Prudential Norms 1. The Core Dispute: RBI Norms vs. Commercial Reality The assessee, a Non-Banking Financial Company (NBFC), claimed that interest on certain loans was not taxable because the underlying advances had been classified as Non-Performing Assets (NPAs) under the RBI Prudential Norms.… Read More »
Comprehensive Ruling on Business Deductions, R&D Weighted Claims, and Intangible Asset Depreciation 1. Software Licence Fees: Revenue vs. Capital Expenditure Title: [Allowability of Software Licence Fees as Revenue Expenditure for Efficient Business Conduct] The assessee incurred costs for application software licences with short useful lives (mostly up to two years) requiring frequent renewal. The Ruling:… Read More »
Quashing of Reassessment Proceedings Due to Issuance of Section 148 Notice by Jurisdictional Officer Instead of Faceless Assessing Officer 1. The Core Dispute: JAO vs. FAO (The Jurisdiction Battle) The assessee challenged the entire chain of reassessment proceedings—starting from the preliminary notice under Section 148A(b) to the final assessment order and demand under Section 156.… Read More »