IMPORTANT INCOME TAX UPDATE 05.12.2025
| Section | Case Law Title | Brief Summary | Citation | Relevant Act |
| 4 | Maruti Suzuki India Ltd. v. DCIT | Sales tax incentives/subsidies received under a State scheme are treated as capital receipts, not taxable as revenue receipts under Section 28(iv). | Click Here | Income-tax Act, 1961 |
| 9 | Maruti Suzuki India Ltd. v. DCIT | Payments for imports on FOB terms (title passed outside India) are not subject to withholding tax. PE/Profit attribution issues belong under Transfer Pricing, not withholding tax provisions. | Click Here | Income-tax Act, 1961 |
| 14A | Maruti Suzuki India Ltd. v. DCIT | Disallowance of interest is unwarranted if investments are made from surplus funds. Administrative cost disallowance is limited only to investments actually yielding exempt income. | Click Here | Income-tax Act, 1961 |
| 35 | Maruti Suzuki India Ltd. v. DCIT | Weighted deduction for in-house R&D allowed despite minor procedural lapses (Form 3CL approval issues) since the facility was recognized under Form 3CM. | Click Here | Income-tax Act, 1961 |
| 36(1)(va) | Spectrum Talent Management v. ACIT | Matter restored to AO to verify if employee PF contributions were made within the due date including the grace period allowed by the PF Act. | Click Here | Income-tax Act, 1961 |
| 37(1) | Spectrum Talent Management v. ACIT | Ad hoc disallowance of 10% on travel/telephone expenses deleted as no specific discrepancies were found in audited books. | Click Here | Income-tax Act, 1961 |
| 37(1) | Ocean Sparkle Ltd. v. DCIT | Reassessment (Sec 263) set aside; allocation of expenses between Tonnage and Non-Tonnage divisions based on turnover ratio was correct. Irrecoverable advances are allowable as revenue deduction. | Click Here | Income-tax Act, 1961 |
| 37(1) | Maruti Suzuki India Ltd. v. DCIT | Ad hoc disallowance of common facility expenses alleging benefit to subsidiaries is unsustainable without specific findings that expenses were not for the assessee’s business. | Click Here | Income-tax Act, 1961 |
| 37(1) | Maruti Suzuki India Ltd. v. DCIT | CSR expenditure incurred for brand promotion and community interface prior to 01.04.2015 is allowable as business expenditure. | Click Here | Income-tax Act, 1961 |
| 37(1) | Maruti Suzuki India Ltd. v. DCIT | Year-end provisions for price adjustments payable to suppliers (based on contracts) are accrued liabilities and allowable, not contingent. | Click Here | Income-tax Act, 1961 |
| 37(1) | Maruti Suzuki India Ltd. v. DCIT | Royalty payments and R&D cess on royalty are revenue in nature and allowable as business expenditure. | Click Here | Income-tax Act, 1961 |
| 37(1) | ITO v. Govindam Agro Foods (P.) Ltd. | Ad hoc 30% disallowance for lack of PAN/address deleted as assessee produced bills, vouchers, and ledgers establishing genuineness. | Click Here | Income-tax Act, 1961 |
| 37(1) | ITO v. Govindam Agro Foods (P.) Ltd. | Provision for audit fees certified in audited accounts is allowable; addition for lack of further evidence is unjustified. | Click Here | Income-tax Act, 1961 |
| 40A(3) | ITO v. Govindam Agro Foods (P.) Ltd. | Disallowance not warranted where payments exceeding limits were made through banking channels, not cash. | Click Here |
Income-tax Act, 1961 |
| 41(1) | ITO v. Govindam Agro Foods (P.) Ltd. | Section 41(1) cannot be invoked for cessation of liability on unsecured loans taken for capital purposes before the commencement of commercial activity. | Click Here | Income-tax Act, 1961 |
| 43B | Maruti Suzuki India Ltd. v. DCIT | Statutory duties (Excise, R&D cess, Customs) and MODVAT differences are allowable deductions under Sec 43B/145A. | Click Here | Income-tax Act, 1961 |
| 43B | Maruti Suzuki India Ltd. v. DCIT | Matter remanded to AO to verify claims regarding excise duty balances in RG 23A Part II and duty paid on consumed inputs. | Click Here | Income-tax Act, 1961 |
| 45 | Maruti Suzuki India Ltd. v. DCIT | Gains from surplus funds invested in mutual funds (treasury practice) are Capital Gains, not business income (CBDT Circular No. 6/2016 applies retrospectively). | Click Here | Income-tax Act, 1961 |
| 54F | Daulat Singh Haldea v. ITO | 100% exemption allowed where new house was purchased jointly with son (suffering from schizophrenia) for convenience; assessee paid the entire consideration. | Click Here | Income-tax Act, 1961 |
| 68 | PCIT v. Surendra B. Jiwrajka | Addition of LTCG as income under Sec 153A deleted as no incriminating material was found during search. | Click Here | Income-tax Act, 1961 |
| 69A | Ador Welding Ltd. v. DCIT | Matter regarding unaccounted sales from non-filer parties remitted to AO for verification of additional documents (invoices/e-way bills) filed during appeal. | Click Here | Income-tax Act, 1961 |
| 92C | Maruti Suzuki India Ltd. v. DCIT | Where TNMM is applied at entity level and profit is at arm’s length, separate TP adjustment for royalty payment is unwarranted. | Click Here | Income-tax Act, 1961 |
| 147 | Srinivasa Services v. Assessment Unit | Jurisdictional Assessing Officer (JAO) has no jurisdiction to initiate proceedings under Sec 148A/148 after the Faceless Scheme came into effect (29-3-2022). | Click Here | Income-tax Act, 1961 |
| 148 | Khurshid Ahmad Dar v. ITO | Reassessment quashed as bad in law where notice lacked AO’s signature, did not follow amended 148A procedure, and was served late/improperly. | Click Here | Income-tax Act, 1961 |
| 148A | Sooriya Hospital v. DCIT | Notice under Sec 148A invalid where it relied on prior year’s data rather than information pertaining to the relevant assessment year. | Click Here | Income-tax Act, 1961 |
| 149 | Vishwa Realty Ltd. v. Assessment Unit | Reopening notice issued on 25-6-2021 for AY 2015-16 is invalid as TOLA extension does not apply. | Click Here | Income-tax Act, 1961 |
| 149 | Sachin Panchal v. DCIT | For searches after 31-3-2021, limitation period for Sec 148 notice aligns with Sec 153A period; reassessment covers 10 years for escaped income. | Click Here | Income-tax Act, 1961 |
| 158B | Surabhi Shelters (P.) Ltd. v. DCIT | Retracted statement of MD without incriminating material found during search cannot be the sole basis for block assessment addition. | Click Here | Income-tax Act, 1961 |
| 269T | Sant Baba Sunder Singh Ji Can. Char. Trust v. CIT | Penalty under Sec 271E justified where the assessee trust repaid unsecured interest-free loans/advances in cash. | Click Here | Income-tax Act, 1961 |
| 271(1)(c) | Abdul Jabbar Jaheer Husain v. ITO | Penalty for concealment deleted; mere disallowance of Sec 54F claim due to lack of some vouchers does not amount to furnishing inaccurate particulars. | Click Here | Income-tax Act, 1961 |
For More :- Read IMPORTANT INCOME TAX CASE LAWS 04.12.2025