IMPORTANT INCOME TAX CASE LAWS 09.01.2026

Relevant Act	Section	Case Law Title	Brief Summary	Citation
Income-tax Act, 1961	Section 2(24)(xviii)	Shriniwas Engineering Auto Components (P.) Ltd. v. ACIT	Subsidy received under Package Scheme of Incentives, 2007 (stamp/electricity duty exemption) was held to be taxable income under Section 2(24)(xviii) in the year of receipt, as it was not directly linked to the acquisition of a fixed asset.	Click Here
Income-tax Act, 1961	Section 9 / DTAA	Outsystems Singapore Pte. Ltd. v. DCIT	Software license fees for standardized software (without transfer of copyright or specialized knowledge) are not Fees for Technical Services (FTS) under the India-Singapore DTAA as the “make available” condition is not met.	Click Here
Income-tax Act, 1961	Section 143(3)	Outsystems Singapore Pte. Ltd. v. DCIT	An assessment order passed under ‘E-Proceedings’ but signed manually (instead of digitally) suffers from an incurable defect and is liable to be quashed, as per CBDT Instruction No. 1/2018.	Click Here
Income-tax Act, 1961	Section 2(14)	Income-tax Officer v. Amira Apparels Ltd.	Claim that land sold was agricultural (not a capital asset) cannot be accepted based solely on revenue records. Substantive evidence of actual agricultural activity is required; matter remanded for factual verification.	Click Here
Income-tax Act, 1961	Section 50	Income-tax Officer v. Amira Apparels Ltd.	Where land and factory building are sold together, capital gains on the depreciable asset (building) must be computed under Section 50 (Short Term Capital Gain). No indexation is available for the building portion.	Click Here
Income-tax Act, 1961	Section 21 (CA Act)	Council of ICAI v. Kishan Gupta	A Chartered Accountant (also Chairman/Director of a company) found guilty of facilitating irregular share allotment detrimental to the public was suspended from ICAI membership for one year.	Click Here
Income-tax Act, 1961	Section 36(1)(vii)	M. Sons Gems N Jewellery (P.) Ltd. v. ACIT	Bad debts claimed for amounts receivable from overseas buyers are allowable, provided the assessee verifies that these amounts were offered as income in earlier years.	Click Here
Income-tax Act, 1961	Section 143 / 170A	Bajaj Electricals Ltd. v. ACIT	Once a modified return (Section 170A) is filed post-merger and considered in the original assessment, the AO becomes functus officio. Issuing a fresh notice to reassess income based on the same return is without jurisdiction.	Click Here
Income-tax Act, 1961	Section 149 / TOLA	Kandasamy Veluswamy v. ACIT	Notice under Section 148 (new regime) issued on 29-07-2022 for AY 2014-15 is valid. The original notice (30-06-2021) was within the TOLA limitation, and under the Ashish Agarwal ruling, it revived the proceedings, making the subsequent notice timely.	Click Here
Income-tax Act, 1961	Section 69A	Shalaka Chandrahas Chavan v. ITO	Cash deposited in a bank account, sourced from the sale of immovable property (evidenced by a registered sale deed), cannot be treated as unexplained money merely because the return filed was treated as invalid on technical grounds.	Click Here

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