INCOME TAX CASE LAW 17.09.2026

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Income-tax Act, 1961	Section 11	Sou Taradevi Asopa Foundation v. ITO	Click Here	Delay of 22 days in filing Form 10B audit report cannot lead to denial of Section 11 exemption if the report was available with CPC prior to processing the return under Section 143(1).
Income-tax Act, 1961	Section 35	Bhansali Engineering Polymers Ltd. v. Circle 1(2)(1)	Click Here	DSIR approval and Form No. 3CL are not mandatory prerequisites to claim capital expenditure deduction for scientific research under Section 35(1)(iv) read with Section 35(2).
Income-tax Act, 1961	Section 37(1)	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	Click Here	Stock exchange charges paid for operational/procedural lapses under regulations are compensatory in nature and thus allowable as business expenditure under Section 37(1).
Income-tax Act, 1961	Section 48	Loonchand Dhanraj HUF v. Assistant Commissioner of Income-tax	Click Here	Reopening an assessment on the exact same share transaction issues previously scrutinized with furnished documents constitutes a mere change of opinion and must be set aside.
Income-tax Act, 1961	Section 68	R.A Shah and Co. v. Deputy Commissioner of Income-tax	Click Here	Additions under Section 68 cannot be made based solely on search statements of unrelated third parties when the assessee substantiated loan repayments with ITRs and bank statements.
Income-tax Act, 1961	Section 68	Mayur Govindbhai Patel v. Income-tax Officer	Click Here	Deletion of Section 68 additions by CIT(A) based on the AO’s own remand report and record will be upheld if the Revenue fails to produce counter-evidence.
Income-tax Act, 1961	Section 68	Manpreet Estates LLP v. ACIT	Click Here	Reassessment proceedings for pre-approval periods stand extinguished if the NCLT approves an IBC resolution plan where the Revenue made no claim.
Income-tax Act, 1961	Section 80	Project Revolt LLP v. Income-tax Officer	Click Here	An LLP mandatorily subject to audit under the LLP Act qualifies for the extended audit due date under Section 139 and is entitled to carry forward business losses accordingly.
Income-tax Act, 1961	Section 80	Project Revolt LLP v. Income-tax Officer	Click Here	CPC’s erroneous application of a non-audit due date to an audited LLP is an error apparent from the record, rectifiable under Section 154 to allow carry forward of losses.
Income-tax Act, 1961	Section 124	Mayur Govindbhai Patel v. Income-tax Officer	Click Here	Reassessment proceedings initiated by an ITO lacking pecuniary jurisdiction under prevailing CBDT instructions are void ab initio and must be quashed.
Income-tax Act, 1961	Section 143	R.A Shah and Co. v. Deputy Commissioner of Income-tax	Click Here	Failure to issue notice under Section 143(2) prior to completing a reassessment makes the resulting assessment order invalid in law.
Income-tax Act, 1961	Section 194A	Amit Gupta v. Sandeep Gupta	Click Here	Balance confirmations and TDS deductions on loan interest can extend limitation periods under Sections 18/19 of the Limitation Act, preventing rejection of a recovery suit at the threshold.
Income-tax Act, 1961	Section 199	Vinayaka S Veerabasappa v. ITO, Ward – 1	Click Here	Credit for TDS appearing in Form 26AS cannot be denied merely because it was omitted in the original return and subsequently claimed via Section 154 rectification.
Income-tax Act, 1961	Section 250	Suryakant Shantaram Bane v. Deputy Commissioner of Income-tax	Click Here	Appeals filed late due to pursuing Section 264 revision and non-receipt of orders from an incorrect email address establish sufficient cause for condonation of delay.
Income-tax Act, 1961	Section 254	Crest Paper Mills Ltd. v. Deputy Commissioner of Income-tax	Click Here	Remanded to Tribunal to evaluate compliance with Rule 29 regarding additional paper books filed alongside an affidavit.
Income-tax Act, 1961	Section 260A	Principal Commissioner of Income-tax v. Pricewaterhouse Coopers (P.) Ltd.	Click Here	Inordinate appeal delay of 1116 days (post-COVID extension) without sufficient, substantiated cause warrants refusal of condonation and dismissal of the appeal.
Income-tax Act, 1961	Section 270A	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	Click Here	Penalty under Section 270A cannot be levied on a bona fide claim based on jurisdictional High Court rulings simply because the deduction was disallowed retrospectively.
Income-tax Act, 1961	Section 271(1)(c)	Principal Commissioner of Income-tax Central 1 Mumbai v. Hasmukh I Gandhi	Click Here	A cyclostyled penalty show-cause notice where irrelevant limbs are not struck off is vague and invalid to form the basis of a Section 271(1)(c) penalty.