INCOME TAX CASE LAW 23.07.2026

Section	Case Law Title / Ref.	Brief Summary	Citation	Relevant Act
Rule 157	Notification No. 94/2026	CBDT widened the definition of ‘specified fund’ under Rule 157 to include Cat-I and Cat-II AIFs regulated by SEBI/IFSCA in an IFSC, alongside Schedule VI funds.	Click Here	Income-tax Rules, 2026 / Income-tax Act, 2025
Section 2(14)	Narayanan Sundaramahalingam Rajkumar v. ACIT	Sale of land near municipal limits constitutes a capital asset when the assessee fails to counter findings regarding population/distance criteria.	Click Here	Income-tax Act, 1961
Section 2(15)	Yashaswi Academy for Skills v. PCIT (Central)	Structured skill development/theoretical training under NEEM/NAPS schemes constitutes “education”; incidental business elements do not justify cancellation of 12AB registration.	Click Here	Income-tax Act, 1961
Section 2(15)	DIT (Exemption) v. Ahmedabad Urban Development Authority	Sale of plots while offering public utility services retains its charitable character under general public utility; 12AA cancellation is unsustainable.	Click Here	Income-tax Act, 1961
Section 10(38)	Vinita Ravi Jain v. ITO	Reopening of assessment based on factually incorrect grounds (erroneously naming an unrelated penny stock company) is invalid and liable to be quashed.	Click Here	Income-tax Act, 1961
Section 12AA	Yashaswi Academy for Skills v. PCIT (Central)	Invoking Sections 12AA(3)/(4) to cancel registration post April 1, 2021, is void as Section 12AA(5) makes Section 12AA inoperative from that date onward.	Click Here	Income-tax Act, 1961
Section 12AB	Yashaswi Academy for Skills v. PCIT (Central)	Sharing surplus via MOU for hospitality skill training with state bodies does not equate to running a commercial hotel business; cancellation of 12AB is unwarranted.	Click Here	Income-tax Act, 1961
Section 12AB	Yashaswi Academy for Skills v. PCIT (Central)	Procedural lapses (like paying cash stipends backed by vouchers under NEEM/NAPS) do not constitute “specified violations” justifying cancellation under 12AB(4).	Click Here	Income-tax Act, 1961
Section 12AB	Yashaswi Academy for Skills v. PCIT (Central)	The “specified violation” regime under Section 12AB(4) introduced on April 1, 2022, cannot be applied retroactively to acts prior to that date.	Click Here	Income-tax Act, 1961
Section 12AB	Yashaswi Academy for Skills v. PCIT (Central)	Alleged violations under Section 13(1)(c)/(d) do not fall within the definition of “specified violations” under Explanation to Section 12AB(4).	Click Here	Income-tax Act, 1961
Section 36(1)(va)	Oswal Transformers (P.) Ltd. v. ITO	Belated deposit of employee contribution to PF/ESI after statutory due dates under respective Acts must be disallowed.	Click Here	Income-tax Act, 1961
Section 36(1)(vii)	Shriram Finance Ltd. v. PCIT	Accepting bad debt claims and IndAS lease expenses without examination renders an order erroneous and prejudicial to revenue under Section 263.	Click Here	Income-tax Act, 1961
Section 37(1)	Oswal Transformers (P.) Ltd. v. ITO	Software maintenance and brokerage expenses paid to related parties are disallowable if unevidenced or lacking proof of actual services rendered.	Click Here	Income-tax Act, 1961
Section 40A(2)	Oswal Transformers (P.) Ltd. v. ITO	Disallowing loan interest paid to a related party by netting it against current trade accounts is invalid unless proved to exceed fair market value; no notional interest addition is permitted.	Click Here	Income-tax Act, 1961
Section 48	Narayanan Sundaramahalingam Rajkumar v. ACIT	On-money additions are restricted only to admitted/proven amounts; reasonable estimation (e.g., 70%) for land improvement costs should be allowed even if old bills are incomplete.	Click Here	Income-tax Act, 1961
Section 68	Srinivasan Bhaskar v. ACIT	Reassessment additions for alleged suppressed receipts are unsustainable if based on third-party search info without incriminating material found with the assessee or rejection of books.	Click Here	Income-tax Act, 1961
Section 69	Virendra Naginbhai Patel (HUF) v. ITO	Disclosure of property in Wealth Tax returns is not sufficient disclosure for Income Tax; reopening under Section 147 based on ITS information is valid.	Click Here	Income-tax Act, 1961
Section 69A	Shiv Kumar Gupta HUF v. DCIT/ACIT	Issuing a single consolidated satisfaction note for multiple assessment years under Section 153C vitiates proceedings; separate notes are legally mandatory per AY.	Click Here	Income-tax Act, 1961
Section 69C	PCIT v. Bhagat Marketing (P.) Ltd.	Restricting disallowance to 12.5% on defective/bogus goods returns represents a plausible view; Section 263 revision for a 100% disallowance is unjustified.	Click Here	Income-tax Act, 1961
Section 80P	Bharat Electronics MC Unit Employees Co-op. Credit SOC Ltd. v. CCIT	Condonation of delay in filing returns for Section 80P deduction should be granted liberally when handled by minimally trained staff, per CBDT Circular 13/2023.	Click Here	Income-tax Act, 1961
Section 144B	Monika Sharma v. AO (NaFAC)	Relying on facts/figures from a different assessment year in a reassessment SCN violates natural justice, requiring the assessment order to be set aside.	Click Here	Income-tax Act, 1961
Section 149	Ashok Madhavdas Khurana v. ACIT	Section 148 notices issued beyond the maximum 10-year outer time limit (including the year of search) are barred by limitation and must be quashed.	Click Here	Income-tax Act, 1961
Section 201	Dr. Reddy’s Laboratories Ltd. v. DCIT	Dismissing a Section 201 appeal as time-barred without offering a requested personal or virtual hearing violates principles of natural justice.	Click Here	Income-tax Act, 1961
Section 251	ITO v. AL Safa Foods	CIT(A) lacks power under Section 251(1)(a) to restore/remand an assessment back to the AO unless it is a best-judgment assessment under Section 144.	Click Here	Income-tax Act, 1961
Section 263	Shriram Finance Ltd. v. PCIT	PCIT has full competency to revise faceless assessment orders under Section 263 if the order lacks proper verification of expenses and claims.	Click Here	Income-tax Act, 1961
Section 270A	Indo-Russian Helicopters Ltd. v. ITO	Inadvertent full deduction of pre-incorporation expenses (instead of 1/5th under 35D) without intentional default or clear specification of the limb does not attract Section 270A penalty.	Click Here	Income-tax Act, 1961
Section 270A	Nalli Trust v. DCIT	Penalty under Section 270A cannot be levied on estimated additions, voluntary disclosures without incriminating material, or where quantum assessments are quashed.	Click Here	Income-tax Act, 1961
Section 277	Sashi Bhusan Prasad Bhuian v. State of Jharkhand	Claiming refunds using forged TDS certificates and fake home loan claims warrants conviction under Section 277 due to wilful attempt to evade tax.	Click Here	Income-tax Act, 1961
Section 277	ITO v. Qamruddin	Persons convicted under Section 277 cannot be released on probation because Section 292A explicitly bars the application of the Probation of Offenders Act / Sec 360 CrPC.	Click Here	Income-tax Act, 1961
Section 292B	MD Sons v. ITO	Minor format non-conformities in Section 143(2) notices relative to CBDT instructions are procedural defects cured under Section 292B, keeping assessment valid.	Click Here	Income-tax Act, 1961