| Section 508 |
Notification 2 of 2026 |
Guidelines issued for Registrars and Share Transfer Agents (RTAs) detailing format and procedure for half-yearly SFT reporting of Mutual Fund transactions to pre-fill capital gains in ITRs. |
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Income-tax Act, 2025 |
| Section 508 |
Notification 1 of 2026 |
Guidelines issued for depositories detailing format and procedure to report SFT capital gains on transfer of listed securities and mutual fund units. |
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Income-tax Act, 2025 |
| Section 11 |
Acc Diamond Jubilee Education Trust v. Exem. ITO |
Income accumulation up to 15% under Sec 11(1)(a) does not require exercising an option in Form 9A; statutory accumulation cannot be denied without specific adverse findings. |
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Income-tax Act, 1961 |
| Section 11 |
Acc Diamond Jubilee Education Trust v. Exem. ITO |
Form 9A filed within the extended return due date is valid; deemed application of income under Sec 11 cannot be denied for not filing it two months prior to the original due date. |
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Income-tax Act, 1961 |
| Section 12A |
Jai Shri Ram Anath Gaushala Samiti v. CIT (Exemption) |
Merely filing return in Form ITR-7 without examining contents or confirming exemption claim does not render a Sec 12A registration application non-maintainable. |
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Income-tax Act, 1961 |
| Section 36(1)(iii) |
Bachangada Nachappa Monnappa v. DCIT |
Interest on borrowings used to acquire assets under IBC held as stock-in-trade for sale is allowable as revenue expenditure under Sec 36(1)(iii); proviso does not apply as assets were not put to use. |
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Income-tax Act, 1961 |
| Section 36(1)(va) |
Royal Chains (P.) Ltd. v. DCIT |
Reassessment initiated solely due to delayed deposit of employee PF/ESIC before the due date of return (under pre-30-03-2021 law) is invalid for lack of reason to believe income escaped assessment. |
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Income-tax Act, 1961 |
| Section 36(1)(va) |
Metso Outotec India (P.) Ltd. v. DCIT |
Employee PF contributions deposited on the next working day after delay caused by bank holidays cannot be disallowed under Sec 36(1)(va). |
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Income-tax Act, 1961 |
| Section 37(1) |
Bachangada Nachappa Monnappa v. DCIT |
Loan processing charges, professional fees, property tax, and scrutiny charges incurred to acquire/sell IBC assets held as stock-in-trade are allowable revenue expenditures under Sec 37(1). |
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Income-tax Act, 1961 |
| Section 68 |
Royal Chains (P.) Ltd. v. DCIT |
Reassessment based on third-party Sec 131 statements lacking any nexus or live link to the assessee or transaction is invalid and liable to be quashed. |
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Income-tax Act, 1961 |
| Section 69A |
Goutham Kumar Pukhraj Jain v. DCIT |
Seized jewellery backed by prior Wealth-tax returns, invoices, and bank records exceeding seized quantities cannot be added as unexplained money merely for lack of item-wise matching. |
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Income-tax Act, 1961 |
| Section 69A |
Goutham Kumar Pukhraj Jain v. DCIT |
Cash found matching undisputed opening balances in past returns cannot be added under Sec 69A based on the assumption that cash was consumed in the interim. |
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Income-tax Act, 1961 |
| Section 69A |
Mrs Neeru Sehgal v. PCIT |
Reassessment notice issued on a cash payment transaction previously examined and accepted during Sec 143(3) scrutiny amounts to an impermissible change of opinion. |
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Income-tax Act, 1961 |
| Section 80-IE |
PCIT v. Sun Pharma Sikkim |
Arbitrary reductions of Sec 80-IE deduction by estimating royalties/management fees without identifying specific defects in audited books or proof of excessive profits are unsustainable. |
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Income-tax Act, 1961 |
| Section 80-IE |
PCIT v. Sun Pharma Sikkim |
Sec 80-IE deduction cannot be denied alleging splitting up/use of old machinery (>20%) based on mere presumptions without evidentiary proof. |
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Income-tax Act, 1961 |
| Section 92B |
KEC International Ltd. v. DCIT |
Corporate and performance guarantee fee for overseas AEs restricted to 0.60% p.a. in line with consistent past Tribunal orders in the assessee’s own case. |
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Income-tax Act, 1961 |
| Section 145 |
JCIT (OSD) v. Rudra Buildwell Homes (P.) Ltd. |
Revenue mismatch between Income-tax returns (Percentage of Completion Method) and Service Tax records alone cannot justify additions when audited books/3CD show no defects. |
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Income-tax Act, 1961 |
| Section 194LA |
Kamalakar v. Karnataka Neeravari Nigam Ltd. |
Compulsory land acquisition compensation is not subject to TDS under applicable provisions; withheld TDS amounts must be released to the recipient. |
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Income-tax Act, 1961 |
| Section 199 |
KEC International Ltd. v. DCIT |
AO directed to verify submitted supporting evidence and grant remaining eligible TDS/TCS credits as per law. |
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Income-tax Act, 1961 |
| Section 270A |
Ghanta Srinivas v. DCIT |
Penalty under Sec 270A quashed due to non-application of mind where show-cause notice failed to specify the applicable sub-clause of Sec 270A(9). |
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Income-tax Act, 1961 |
| Section 271AAD |
Ghanta Srinivas v. DCIT |
Penalty under Sec 271AAD applies to fake invoice/fraudulent entries, not to undisclosed cash professional receipts voluntarily surrendered during search. |
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Income-tax Act, 1961 |
