IMPORTANT INCOME TAX CASE LAWS 01.12.25

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IMPORTANT INCOME TAX CASE LAWS 01.12.25

SectionCase Law TitleBrief SummaryCitationRelevant Act
12AHarmony Educational Foundation v. Commissioner of Income-tax (Exemption)Commissioner (Exemption) was justified in rejecting the registration of an assessee running a school without competent authority approval, charging high fees, earning high profits, and having non-charitable objects.Click HereIncome-tax Act, 1961
14APrincipal Commissioner of Income-tax v. EYGBS (India) (P.) LtdDisallowance under section 14A for expenditure related to exempt dividend income from mutual funds was deleted when the investments were made and liquidated within the year, resulting in no opening/closing balances, and the disallowance was ad hoc.Click HereIncome-tax Act, 1961
36(1)(va)FIL India Business & Research Services (P.) Ltd. v. Assessment Unit Income-tax DepartmentDisallowance of employee’s contribution to PF was deleted when payment was made by the assessee within the stipulated date and debited in their bank, but not credited to the EPFO account due to technical glitches beyond the assessee’s control.Click HereIncome-tax Act, 1961
68Mukesh Vallabhdas Shah v. Income-tax OfficerGains from share transactions traded through the stock exchange were not treated as unexplained cash credit as the assessee discharged their onus by providing complete documentary evidence (purchase/sale details, broker certificate).Click HereIncome-tax Act, 1961
69 & 44ADNikita Gupta v. Income-tax OfficerNo addition was made for cash deposits up to Rs. 2 lakhs (out of Rs. 2.5 lakhs deposited) by a small gold dealer during demonetization who offered presumptive income under section 44AD, citing CBDT Instruction No. 3/2017.Click HereIncome-tax Act, 1961
80PDistrict Co-operative Sugar Cane Supply Ltd v. Income-tax OfficerTwo points: 1) Deduction under section 80P for interest on FDs made to comply with statutory reserve requirements requires recomputation with reference to interest earned on such investments. 2) Addition made on unoffered commission income was deleted as the full commission/grant receivable qualified for deduction under section 80P.Click HereIncome-tax Act, 1961
92C (TP Method)Netflix Entertainment Services india LLP v. Deputy Commissioner of Income-taxAssessee, a limited-risk distributor of a global OTT platform, was wrongly reclassified by the TPO as an entrepreneurial entity; the TNMM (Transactional Net Margin Method) remained the most appropriate method, and the ‘Other Method’ adopted by the TPO was unsustainable.Click HereIncome-tax Act, 1961
92C (Turnover Filter)FIL India Business & Research Services (P.) Ltd. v. Assessment Unit Income-tax DepartmentAO/TPO was directed to re-consider comparables by properly applying the turnover filter (Rs. 4 to 5 crores) and exclude a company that failed this filter (turnover of Rs. 3.65 crores).Click HereIncome-tax Act, 1961
92C (TP Adjustment & Sec. 10AA)Principal Commissioner of Income-tax v. EYGBS (India) (P.) LtdAssessee having a SEZ unit and eligible for section 10AA deduction who voluntarily offered TP adjustments in returns (as per an APA) could not be denied the section 10AA exemption on the income relating to those adjustments, as the income was not enhanced by the AO.Click HereIncome-tax Act, 1961
143Nikita Gupta v. Income-tax OfficerIssue regarding non-credit of pre-paid self-assessment tax (Rs. 21,700) was remanded back to the AO for necessary verification.Click HereIncome-tax Act, 1961
158BCJoint Commissioner of Income-tax (OSD) v. H B Leasing & Finance Company Ltd.Addition for disallowed losses on sale of shares in a block assessment was deleted as all transactions were duly recorded in books and disclosed in returns, and no single transaction was found undisclosed.Click HereIncome-tax Act, 1961
159Anita Rani v. Income-tax OfficerAttachment of the joint bank account of the wife of a deceased partner for recovery of the firm’s dues was unjustified and set aside, as there was no evidence she inherited any estate from the partners and liability under section 159 did not arise.Click HereIncome-tax Act, 1961
201 & 40(a)(i)Netflix Entertainment Services india LLP v. Deputy Commissioner of Income-taxSince the assessee opted for settlement of the appeal under section 201/201(1A) by availing the Vivad se Vishwas Scheme-2020, the disallowance under section 40(a)(i) made by DRP in the assessment would not survive (as per CBDT Circular No. 12 of 2024).Click HereIncome-tax Act, 1961
270ADeputy Commissioner of Income-tax v. Ethirajulu Vajravel KumaranPenalty levied under section 270A was deleted as the impugned notice did not delineate which particular limb or clause of section 270A(9) was attracted.Click HereIncome-tax Act, 1961
271(1)(c)Deputy Commissioner of Income-tax v. Ethirajulu Vajravel KumaranPenalty under section 271(1)(c) was deleted where the assessee voluntarily offered additional income in compliance with a section 153A notice, and the disclosure was not based on any incriminating material found during the search.Click HereIncome-tax Act, 1961
271AABDeputy Commissioner of Income-tax v. Ethirajulu Vajravel KumaranPenalty order under section 271AAB(1A) was legally unsustainable as the Assessing Officer failed to specify the relevant limb of the section in the notice.Click HereIncome-tax Act, 1961

For More :- Read IMPORTANT INCOME TAX CASE LAWS 29.11.2025