| Section 40(a)(ia) |
ACIT vs. Orbit Ventures Developers |
Expenditure that is capitalized to Work-in-Progress (WIP) and not claimed in the Profit & Loss account cannot be disallowed under section 40(a)(ia) in the current year. It can only be adjusted within the WIP itself. |
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Income-tax Act, 1961 |
| Section 143(1), 143(3) & 154 |
General Mills India (P.) Ltd. vs. Deputy Commissioner of Income-tax |
Appeals against a Sec 143(1) intimation and a Sec 143(3) assessment order must be heard together by the CIT(A) to avoid multiplicity of proceedings and duplicity of income additions. |
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Income-tax Act, 1961 |
| Principles of Consistency / Estoppel |
Principal Commissioner of Income-tax-7 vs. Samsung India Electronics (P.) Ltd. |
Revenue’s subsequent appeals are maintainable if a past failure to challenge an issue (expatriate remuneration) occurred solely due to an AO’s oversight, making that specific prior year an exception to the rule of consistency. |
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Income-tax Act, 1961 |
| Assessment Proceedings / Capital Gains |
Balchandra Builders (P.) Ltd. vs. Deputy Commissioner of Income-tax |
An exemption claim for the sale of agricultural land must be adjudicated on its merits if the revised computation is on record, even if the assessee failed to file a formal revised return. |
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Income-tax Act, 1961 |
| Bogus Purchases |
Principal Commissioner of Income-tax vs. Prathana Gems |
An addition for bogus purchases from an entry group was rightly restricted to 6% instead of 100%, keeping in line with a consistent approach upheld by the ITAT in similar cases. |
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Income-tax Act, 1961 |
| Section 14A r.w. Rule 8D |
Deputy Commissioner of Income-tax vs. Trent Ltd. |
Additional disallowance under section 14A is not warranted and should be deleted if the assessee’s suo motu disallowance on identical facts was accepted by the department in earlier years. |
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Income-tax Act, 1961 |
| Section 10(10B) & 10(10C) |
Sameer Yadram Sharma vs. ITO |
Ex-gratia compensation received by employees under the BSNL VRS (2019) is a capital receipt eligible for exemption as retrenchment compensation under section 10(10B), rather than section 10(10C). |
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Income-tax Act, 1961 |
| Section 147 / 148 (Reassessment) |
Mukat Pipes Ltd. vs. ACIT |
Reassessment initiated beyond 4 years on a loan waiver issue is invalid if all primary facts were disclosed during the original assessment; doing so merely amounts to an impermissible change of opinion/review. |
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Income-tax Act, 1961 |
| Section 245 |
Somic Zf Components (P.) Ltd. vs. National Faceless Assessment Centre |
Adjusting tax refunds against an outstanding portal demand without serving a valid assessment order or demand notice is illegal. Such adjustments must be quashed and refunded with interest. |
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Income-tax Act, 1961 |
