IMPORTANT INCOME TAX CASE LAW 09.12.2025

Section	Case Law Title	Brief Summary	Citation	Relevant Act
Section 10A	Principal Commissioner of Income-tax v. Mahindra Engineering Services Ltd.	Deduction under section 10A (Free Trade Zone/STP Unit) cannot be denied if the new unit is independent, set up with fresh infrastructure, new plant/machinery, new software, and a separately recruited workforce, proving it was not formed by splitting up or reconstruction of an existing business.	Click Here	Income-tax Act, 1961
Section 12A	Sir P. T. Sarvajanik College of Science alumni association v. CIT(Exemption)	Rejection of regular registration under section 12A and cancellation of provisional registration were unjustified when the alumni association trust’s objects included overall development of students, relief to the poor, and medical relief, and were not limited solely to benefiting its members.	Click Here	Income-tax Act, 1961
Section 12AB	Shri Surati Modh Ganchi Gnati jilla Nanpura Panch v. Commissioner of Income-tax(Exemption)	Cancellation of trust registration under section 12AB, done without issuing a specific show cause notice or adequately considering submissions, violated the principles of natural justice and must be set aside for fresh consideration after granting a reasonable opportunity of being heard.	Click Here	Income-tax Act, 1961
Section 14A	Acme Cleantech Solutions Ltd. v. Deputy Commissioner of Income-tax	Disallowance of expenditure incurred in relation to exempt income under section 14A must be computed by considering only those investments that actually yielded exempt income.	Click Here	Income-tax Act, 1961
Section 32	Signode India Ltd. v. Deputy Commissioner of Income-tax	Disallowance of depreciation claimed on goodwill arising from an acquisition was rightly sustained, as the issue was already decided against the assessee in an earlier year (AY 2014-15), and the additional evidence presented was not new but was part of records already considered.	Click Here	Income-tax Act, 1961
Section 37(1)	Acme Cleantech Solutions Ltd. v. Deputy Commissioner of Income-tax	A provision for warranty on goods sold, where most of it is utilized in the immediately succeeding year, relates to an ascertained liability and should not be added back to book profits under section 115JB (MAT), subject to verification of actual utilization.	Click Here	Income-tax Act, 1961
Section 43B	HighRadius Technologies (P) Ltd v. Deputy Commissioner of Income-tax	Disallowance of leave encashment under section 43B, based solely on an intimation under section 143(1) that was issued after the initiation of scrutiny (notice under section 143(2)), lacks legal sanctity and cannot be sustained without an independent assessment enquiry.	Click Here	Income-tax Act, 1961
Section 68	Experion Hospitality (P.) Ltd. v. Income-tax Officer	Reassessment proceedings initiated on the ground of unexplained cash credit (share application money from a foreign company) must be quashed if the identity, creditworthiness of the investor, and genuineness of the transaction have already been examined and accepted by the department in subsequent assessment years.	Click Here	Income-tax Act, 1961
Section 68	Acme Cleantech Solutions Ltd. v. Deputy Commissioner of Income-tax	Where the assessee furnished complete documentation (KYC, financials, TRC) for share investment from a foreign company, but the Assessing Officer failed to verify them before making an addition under section 68, the matter is remanded for proper verification.	Click Here	Income-tax Act, 1961
Section 68	Kanchanben Pravinbhai Sheth v. Principal Commissioner of Income-tax	A revisionary order under section 263 is valid when the Assessing Officer accepted the assessee’s claim for Long Term Capital Gain (LTCG) on a “penny stock” without properly examining the credible, specific, and detailed information provided by the Investigation Wing.	Click Here	Income-tax Act, 1961
Section 69A	Jayanta Fanzen Lighting Industries (P.) Ltd. v. ACIT	Addition under section 69A (Unexplained Moneys) for large cash deposits during demonetisation must be deleted if the assessee successfully explains the source, by providing bank statements and a withdrawal-deposit summary showing redeposit of earlier withdrawals, which was also accepted by the Assessing Officer in remand.	Click Here	Income-tax Act, 1961
Section 69A	Smt. Asha Sharma v. Principal Commissioner of Income-tax	Additions under section 69A made solely on the basis of a survey statement recorded under section 133A, which has no evidentiary value, are liable to be set aside if no independent material exists to corroborate the alleged excess cash or stock.	Click Here	Income-tax Act, 1961
Section 69B	Deputy Commissioner of Income-tax v. Abhipush Properties (P.) Ltd.	Reassessment based on additions under section 69C and 69B (Undisclosed Investments/Expenditure) by treating the difference between registered value and figures in an unsigned third-party Excel sheet as on-money paid is quashed, as no independent evidence proved the sheet belonged to the assessee or that on-money was paid.	Click Here	Income-tax Act, 1961
Section 80G	Sir P. T. Sarvajanik College of Science alumni association v. CIT(Exemption)	Rejection of approval under section 80G solely because the registration under section 12A was denied is unsustainable once the denial of 12A registration is set aside. Fresh adjudication on the merits of the 80G application is required.	Click Here	Income-tax Act, 1961
Section 80P	Deputy Commissioner of Income-tax v. Bardoli Vibhag Gram Vikas Co-op. Society Ltd.	An assessee-co-operative society is eligible for deduction under section 80P(2)(d) on interest income earned from fixed deposits kept with a co-operative bank.	Click Here	Income-tax Act, 1961
Section 92B	Signode India Ltd. v. Deputy Commissioner of Income-tax	Outstanding trade receivables from Associated Enterprises (AEs) where no specific credit period or interest is agreed upon, qualify as an international transaction requiring benchmarking. The appropriate interest rate for imputing notional interest should be LIBOR + 200 basis points, after permitting a standard 60-day credit period.	Click Here	Income-tax Act, 1961
Section 92C	HighRadius Technologies (P) Ltd v. Deputy Commissioner of Income-tax	For benchmarking captive software development services: a business consulting and enterprise transformation company, or a company involved in diversified activities, product engineering, R&D, or having a significantly higher turnover/intangibles without relevant segmental data, is not functionally comparable and must be excluded.	[2025] 180 taxmann.com 563 (Hyderabad – Trib.) Double	Income-tax Act, 1961
Section 92C	Acme Cleantech Solutions Ltd. v. Deputy Commissioner of Income-tax	When benchmarking loans advanced to AEs, if the agreement stipulates repayment in US dollars and there are no fresh loans during the year, the application of a LIBOR-based interest rate is appropriate. No separate transfer pricing adjustment is warranted on outstanding receivables if the working capital adjustment is already factored into pricing.	Click Here	Income-tax Act, 1961
Section 148	Snehdham Trust v. Assistant Commissioner of Income-tax	Notices issued by the Jurisdictional Assessing Officer under section 148 (Income Escaping Assessment) after April 1, 2022, are valid and legal, as the procedure under section 144B only refers to faceless assessment and does not mandate faceless issuance of a Section 148 notice.	Click Here	Income-tax Act, 1961
Section 153D	Suresh Kumar Agrawal v. Assistant Commissioner of Income-tax	Approval granted by the competent authority under section 153D (Prior Approval in Search Cases) is void ab initio if it is granted in a mechanical manner without recording any independent satisfaction or reasoning.	Click Here	Income-tax Act, 1961
Section 270A	Manoj Kumar Gangadharan v. Income-tax Officer (IT & TP)	The Commissioner (Appeals) was right to dismiss the first appeal as time-barred (delay of 560 days) against a penalty order under section 270A when the only explanation given—that the assessee was a merchant navy officer on a ship—was not satisfactory for such a long delay.	Click Here	Income-tax Act, 1961
Section 276C	Vilas Babanrao Kalokhe v. Principal Commissioner of Income-tax (Central)	Failure to deposit self-assessment tax before or along with the return, when the tax is subsequently paid, cannot be considered a willful attempt to evade tax; thus, the prosecution launched against the assessee under section 276C(2) must be quashed.	Click Here	Income-tax Act, 1961

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