IMPORTANT INCOME TAX CASE LAWS 05.02.2026

Relevant Act	Section	Case Law Title	Brief Summary	Citation
PBPT Act, 1988	Section 2(9)(A)	DCIT (BPU-2) Mumbai v. Surge Ahead Solutions Pvt. Ltd.	[Non-Application of Mind] Benami allegations failed where the Initiating Officer (IO) attached closed bank accounts and relied on regulatory suspicion without identifying the original benami property or its proceeds. This lack of specific proof led to the revocation of the attachment.	Click Here
PBPT Act, 2016	Section 2(9)	Sri Prabhakar Satpathy v. Initiating Officer	[Nephew’s Funds = Benami] Land purchased in a person’s name using funds entirely from his nephews, and later transferred to them without consideration, was held as Benami. Mere compliance with TDS and stamp duty does not override the “beneficial owner” test.	Click Here
Income-tax Act, 1961	Section 14A	DCIT v. Sahyadri Agencies Ltd.	[The Ceiling Rule] Disallowance u/s 14A read with Rule 8D cannot exceed the actual exempt income earned during the previous year. You cannot disallow more than what you sought to exclude from tax.	Click Here
Income-tax Act, 1961	Section 50 / 50C	Jewelex India (P.) Ltd. v. DCIT	[No 50C on WDV Reduction] Section 50C (Stamp Duty Value) does not apply when reducing the WDV of a Block of Assets. If the sale price is less than the WDV, the actual sale value is reduced from the block; the deeming fiction of S. 50C only applies to the computation of Capital Gains, not WDV.	Click Here
Income-tax Act, 1961	Section 153C	Smt. Geetanjali Bhayana v. DCIT	[Jurisdictional Bar] Reassessment u/s 153C for searches initiated after 01-04-2021 is invalid as this section was subsumed under the new reassessment regime (S. 147-148). Also, undated or vague “satisfaction notes” vitiate the proceedings.	Click Here
Income-tax Act, 1961	Section 205	Arpit Pravinbhai Shah v. ACIT	[TDS Credit Protection] If an employee produces Form-16, the department cannot deny TDS credit or recover tax from them just because the employer failed to deposit it. Any recovered amount must be refunded with interest.	Click Here

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