| N/A (Press Release) |
CBDT Verification Drive on Fake Deductions |
The Income-tax Department launched a nationwide verification drive against individuals, entities, and intermediaries making fraudulent deduction and exemption claims in ITRs. |
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Income-tax Act, 1961 |
| Section 10(46) |
Notification of DLSA & BBN Development Authority |
Central Government notified ‘District Legal Service Authority’ and ‘Baddi Barotiwala Nalagarh Development Authority’ for the purpose of tax exemption under section 10(46). |
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Income-tax Act, 1961 |
| Section 12A |
Kotak Family Foundation v. CIT (Exemption) |
Assessee-trust filed ITR on time and the auditor uploaded Form 10B, but e-verification was delayed due to Covid-19 disruptions. The Commissioner ought to have condoned the delay per CBDT Circular No. 16/2024. |
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Income-tax Act, 1961 |
| Section 12AB |
NSDC Skill Impact Trust v. CIT (Exemptions) |
Trust set up by NSDC for skill development was wrongly denied registration on grounds of charging a 10% management fee; since objects and actual activities were charitable, registration u/s 12A and exemption u/s 80G were directed to be granted. |
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Income-tax Act, 1961 |
| Section 37(1) |
Pankaj Shukla v. ITO |
Disallowance of interest expenditure claimed in P&L account was deleted because nothing in the furnished accounts indicated that the interest pertained to a personal home loan. |
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Income-tax Act, 1961 |
| Section 37(1) |
Bollineni Developers Ltd. v. DCIT |
Assessee produced muster rolls with worker details and signatures for site maintenance; an ad-hoc disallowance of 30% was excessive and reduced to 10% to meet the ends of justice. |
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Income-tax Act, 1961 |
| Section 37(1) |
Underwater Services Company Ltd. v. DCIT |
Disallowance of 25% on victualling expenses (food/boarding on high-sea vessels) made on a purely ad-hoc basis was deleted, as the assessee provided full personnel details and food charts. |
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Income-tax Act, 1961 |
| Section 37(1) |
Underwater Services Company Ltd. v. DCIT |
Assessee had already suo motu disallowed 50% of sundry, sales promotion, and gift expenses; therefore, no further ad-hoc disallowance by the AO was warranted. |
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Income-tax Act, 1961 |
| Section 40A(2) |
Underwater Services Company Ltd. v. DCIT |
Disallowance of 25% charter hire charges paid to holding company was deleted because the AO’s benchmark was flawed (not like-to-like) and actual comparables showed the assessee paid lower rates than third parties. |
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Income-tax Act, 1961 |
| Section 40A(2)(a) |
ITO v. Khetalaji Gold (P.) Ltd. |
Matter remanded to CIT(A) for fresh adjudication because lower authorities disallowed related-party gold purchases without referring to or relying on objective market data/ALP benchmarks. |
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Income-tax Act, 1961 |
| Section 72A / Section 2(19AA) |
PCIT v. NOCIL Ltd. |
Restructuring involved transfer of specific division assets/liabilities for cash consideration rather than share allotment. It did not qualify as a ‘demerger’ u/s 2(19AA); hence, section 72A(4) benefits were not attracted. |
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Income-tax Act, 1961 |
| Section 143 |
Tamil Nadu Power Distribution Corporation Ltd. v. JCIT |
Assessment order set aside and remanded because granting only two days to reply to a comprehensive show cause notice violated principles of natural justice. |
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Income-tax Act, 1961 |
| Section 148A |
Mukul Mahanta v. UOI |
Providing 4 days instead of 7 days (as suggested in CBDT SOP) to respond to a notice u/s 148A(b) did not cause prejudice where the assessee otherwise had sufficient opportunity and legal remedies. |
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Income-tax Act, 1961 |
| Section 159 |
Vinod Kala v. CIT-II |
An executor appointed under a will is covered under the definition of ‘legal representative’ under section 159 and is liable to be assessed for the deceased person’s income earned during their lifetime. |
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Income-tax Act, 1961 |
| Section 271(1)(c) |
Chhattisgarh Steel Castings (P.) Ltd. v. PCIT |
Where unrecorded stock found in an excise survey was admitted as unrecorded sales, the entire unrecorded sales value was taxable as concealed income (not merely gross profit), sustaining penalty u/s 271(1)(c). |
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Income-tax Act, 1961 |
