IMPORTANT INCOME TAX CASE LAWS 20.11.2025

By | November 22, 2025
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IMPORTANT INCOME TAX CASE LAWS 20.11.2025

Section / Notification No.Case Law TitleBrief SummaryCitationRelevant Act
Notification No. 162/2025N/A (CBDT Notification)CBDT authorized 19 banks (including HDFC Bank, ICICI Bank, Axis Bank, City Union Bank, etc.) to receive deposits and maintain accounts under the Capital Gains Account Scheme, 1988.Click HereIncome-tax Act, 1961 (Implied) & Capital Gains Account Scheme, 1988
Notification No. 161/2025N/A (CBDT Notification)CBDT amended the Capital Gains Account Scheme, 1988, to allow the deposit of capital gains by electronic mode and to allow deposits to claim exemption under section 54GA.Click Here Income-tax Act, 1961 (Implied) & Capital Gains Account Scheme, 1988
Section 12AAVijayanagar Educational Trust v. Commissioner of Income-tax (Exemptions)Cancellation of a charitable trust’s registration under section 12AA was quashed because grounds like disputes among trustees, a wrongful depreciation claim (which was an alternative claim), and amendment to trust deed without prior permission were not valid reasons for cancellation under section 12AA(4). Salary payments to family members were also not a valid reason without evidence of excessive payment or lack of services.Click HereIncome-tax Act, 1961
Section 32GMM Pfaulder Ltd. v. Principal Commissioner of Income-taxWhere the AO accepted the claim for depreciation on goodwill arising from business restructuring, the PCIT’s revisionary jurisdiction under section 263 was not justified, as the AO’s view was a plausible view in law, even post-amendment. 

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Income-tax Act, 1961
Section 35Axiomatic iTech (P.) Ltd. v. Income-tax OfficerWhere the CIT(A) passed an ex parte order regarding a deduction claim for donation to a scientific research institution under section 35(1)(ii) without hearing the assessee, the matter was remitted back for de novo adjudication.Click HereIncome-tax Act, 1961
Section 36(1)(va)Ranar Agrochem Ltd. v. Deputy Commissioner of Income-taxDeduction claimed for employees’ contribution to PF/ESI was not allowable if deposited beyond the due date prescribed under the respective Acts.Click HereIncome-tax Act, 1961
Section 37(1)GMM Pfaulder Ltd. v. Principal Commissioner of Income-taxWhere the AO accepted the deduction for provision for warranty based on scientific/historical trends, the PCIT’s revisionary jurisdiction under section 263 was unjustified.Click HereIncome-tax Act, 1961
Section 37(1)LG Electronics India (P.) Ltd. v. Additional Commissioner of Income-taxAssessee’s claim for deduction of provision for service warranty created on a scientific and rational basis was allowable. Salary payments to expatriates directly recruited by the assessee and working exclusively for its business were allowable. Royalty paid to the foreign parent company for the use of technology, know-how, and brand was revenue expenditure.Click HereIncome-tax Act, 1961
Section 40(a)(ia)Ranar Agrochem Ltd. v. Deputy Commissioner of Income-taxDisallowance of provision for tax audit expenses under section 40(a)(ia) was deleted where the AO disallowed it merely because the assessee couldn’t substantiate the payees had paid the corresponding tax on the amount.Click HereIncome-tax Act, 1961
Section 48Gulf Oil Corporation Ltd. v. Assistant Commissioner of Income-taxAmounts paid for termination of an agreement (where the original MoU had no such condition) and commission for sale of land (without evidence of service rendered) were not allowable as expenditure for computing capital gains under section 48.Click HereIncome-tax Act, 1961
Section 50CChhaganbhai Muljibhai Patoliya v. ITOWhere the AO applied section 50C to adopt stamp-duty value but failed to recompute capital gains or allow cost of acquisition and indexation, and the assessee hadn’t submitted complete evidence, the matter was remitted back to the AO for fresh consideration.Click HereIncome-tax Act, 1961
Section 56Deb Prasanna Choudhury v. ADIT/DCIT (International Taxation)A gift received by the assessee from his brother-in-law (spouse of his sister) was not liable to be included in the total income as it was from a relative defined under the Act.Click HereIncome-tax Act, 1961
Section 68Ranar Agrochem Ltd. v. Deputy Commissioner of Income-taxUnsecured loans received from various lenders were rightly treated as unexplained cash credits under section 68 when the assessee failed to substantiate the identity, creditworthiness, and genuineness of the loan transactions for a majority of the lenders.Click HereIncome-tax Act, 1961
Section 69CDCIT v. Amar GhanasinghFor purchases made from entities alleged to be accommodation providers, where sales and stock were accepted, restricting the profit addition to 3% of the disputed non-genuine purchases was held to be in accordance with law, as only the profit element embedded could be taxed.Click HereIncome-tax Act, 1961
Section 80GGMM Pfaulder Ltd. v. Principal Commissioner of Income-taxWhere the AO accepted the deduction claim under section 80G for CSR expenditure (donations to 80G registered institutions), the PCIT’s revisionary jurisdiction under section 263 on the ground that CSR was not business expenditure under Explanation 2 to section 37(1) was unjustified.Click HereIncome-tax Act, 1961
Section 80JJAALG Electronics India (P.) Ltd. v. Additional Commissioner of Income-taxThe second proviso to section 80JJAA(2) (Finance Act, 2018), which makes workmen completing 300 days in the relevant year eligible for deduction, is clarificatory and retrospective. The assessee’s claim for deduction of additional wages was therefore allowable.Click HereIncome-tax Act, 1961
Section 92B/92CLG Electronics India (P.) Ltd. v. Additional Commissioner of Income-taxWhen all international transactions were benchmarked together using TNMM at the entity level, and the TPO accepted this for others, a separate transfer pricing adjustment for AMP expenses based on the bright line test was not warranted. Also, no separate adjustment was warranted for design and development charges where the operating margin was within the permissible range. No mark-up was to be applied on warranty service reimbursements by the AE as it was a cost-to-cost reimbursement. Transfer pricing adjustments for management support costs were deleted based on the Tribunal’s consistent view of proportional allocation in earlier years.Click HereIncome-tax Act, 1961
Section 143Marymatha Province of Vincentian Congregation v. Additional/Joint/Deputy/Assistant Commissioner of Income-tax/Income-tax Officer, NFAC DelhiWhen the assessment notice listed ‘Receipts of Trust’ without limiting the scope, and the revenue’s documents indicated the proceedings were intended as a complete scrutiny, there was no justifiable reason to treat it as a limited scrutiny.Click HereIncome-tax Act, 1961
Section 148AVasuki Global Industrial Ltd. v. Principal Chief Commissioner of Income-taxThe jurisdictional AO has the responsibility to verify information on the Insight Portal suggesting income has escaped assessment and must conduct an inquiry with prior approval before invoking section 148A(1).Click HereIncome-tax Act, 1961
Section 151ABunts Pakirappa Narayana Rai v. Income-tax OfficerReassessment notices issued by a jurisdictional Assessing Officer in contravention of section 151A (Faceless Assessment of Income Escaping Assessment) are obliterated, and consequential proceedings are liable to be quashed.Click HereIncome-tax Act, 1961
Section 194CLG Electronics India (P.) Ltd. v. Additional Commissioner of Income-taxWhere the assessee didn’t deduct TDS on payments to transporters after 01.10.2009 (who furnished PAN as per amended Section 194C(6)), the subsequent disallowance under section 40(a)(ia) due to the Finance Act, 2015 amendment was deleted because the 2015 amendment was prospective and not applicable to the relevant year.Click HereIncome-tax Act, 1961

For More :- Read IMPORTANT GST CASE LAWS 19.11.2025