IMPORTANT INCOME TAX CASE LAWS 31.12.2025

Relevant Act	Section	Case Law Title	Brief Summary	Citation
Income-tax Act, 1961	Section 9	Informatica Business Solutions (P.) Ltd. v. Jt. CIT	Secondment of employees to Indonesia where salary was routed through an Indonesian entity required fresh examination of the secondment agreement to determine the real employer and withholding tax obligations.	Click Here
Income-tax Act, 1961	Section 10B	Halliburton Technology India (P.) Ltd. v. ACIT	Deduction under Section 10B cannot be disallowed in a Section 143(1) intimation due to a technical e-filing glitch, especially when the AO had examined and accepted the claim in regular assessment.	Click Here
Income-tax Act, 1961	Section 11	Dakuben Saremalji Sancheti (Nadol Charitable Trust) v. CIT (Exemptions)	Rejection of condonation for delay in filing Form 10B/10 solely based on CBDT’s three-year limitation was unjustified when the CIT(E) had already accepted COVID-19 as a valid reason for the belated return.	Click Here
Income-tax Act, 1961	Section 28(iv)	Informatica Business Solutions (P.) Ltd. v. Jt. CIT	Reimbursement of realized forex loss on ECB repayment is not taxable as a benefit/perquisite under Section 28(iv) as it is in the shape of money and related to a capital transaction.	Click Here
Income-tax Act, 1961	Section 69B / 263	Vaksons Metaplast (P.) Ltd. v. PCIT	Initiation of revision proceedings under Section 263 on the issue of bogus purchases was bad in law because the same addition was already under challenge before the Commissioner (Appeals).	Click Here
Income-tax Act, 1961	Section 69C	PCIT v. Mohit Pukhraj Kawdiya	Disallowance for bogus purchases was restricted to the profit element (6%) rather than 100% of the purchase value, as factual analysis showed only the profit margin was evaded.	Click Here
Income-tax Act, 1961	Section 72A	CIT v. Eastman Exports Global Clothing Pvt Ltd.	Section 72A(4) (Demerger) does not impose a minimum period of existence condition unlike Section 72A(2) (Amalgamation). PCIT’s revision order treating a demerger as an amalgamation was incorrect.	Click Here
Income-tax Act, 1961	Section 115BBE	ITO v. Mahendrakumar Bhagvandas	The higher tax rate under the amended Section 115BBE (effective 15-12-2016) is not retrospective. For periods prior to this date, the normal tax rate applies for calculating the tax effect for filing appeals.	Click Here
Income-tax Act, 1961	Section 115JB	Bay Forge (P.) Ltd. v. ACIT	For MAT purposes (S. 115JB), the quantum of brought-forward loss is determined at the beginning of the year (1st April). A reduction of share capital during the year cannot retrospectively alter the opening loss position.	Click Here
Income-tax Act, 1961	Section 148A	Gaurang Raghavjibhai Patel v. ITO	Reassessment order passed without granting adequate time to respond to the Section 148A(b) notice (alleging unexplained transactions) was quashed for violation of natural justice.	Click Here
Income-tax Act, 1961	Section 245C	Khazana Jewellery (P.) Ltd. v. ITSC	Settlement Commission cannot partially accept a disclosure. If the manner of earning for a substantial portion (Rs. 80 Cr) is unsubstantiated, the application must be rejected in entirety. The Commission cannot convert it into deemed income under S. 69B/115BBE on its own.	Click Here

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