IMPORTANT INCOME TAX CASE LAWS 12.01.2026

Relevant Act	Section	Case Law Title	Brief Summary	Citation
Income-tax Act, 1961	Section 32 / 37(1)	Spectris Technologies (P.) Ltd. v. ITO	[Non-Compete Fee] Following the landmark SC ruling in Sharp Business System, the AO was directed to treat Non-Compete Fees as Revenue Expenditure (deductible u/s 37) rather than a capital asset eligible for depreciation.	Click Here
Income-tax Act, 1961	Section 92B / 92C	DCIT v. GMR Airports Ltd.	[Corporate Guarantee] Corporate Guarantees and Standby Letters of Credit (SBLC) are International Transactions. However, TP adjustment for SBLC must be restricted to the unrecovered commission cost.	Click Here
Income-tax Act, 1961	Section 92C	Spectris Technologies (P.) Ltd. v. ITO	[Segmental TP] Where a business has distinct segments (e.g., Equipment Supply vs. After-Sales Services) with different risk/asset profiles, benchmarking must be done separately for each segment rather than at the entity level.	Click Here
Income-tax Act, 1961	Section 54B	Pravinsinh Bhawansinh Vaghela v. ITO	[Agri Land Exemption] Expenses incurred on levelling and fencing newly purchased agricultural land are “intrinsically connected” to the acquisition and form part of the cost of acquisition eligible for Section 54B deduction.	Click Here