INCOME TAX CASE LAW 18.09.2026

Section	Case Law Title	Brief Summary	Citation	Relevant Act
Section 5	Seaview Developers (P.) Ltd. v. DCIT	Excess CAM charges collected on estimate and held as ‘advance from customers’ with a contractual duty to adjust/refund via credit notes represent a liability, not taxable income.	Click Here	Income-tax Act, 1961
Section 14A	ACIT v. Zydus Lifesciences Ltd.	For computing disallowance under Section 14A r.w. Rule 8D, only investments yielding exempt income during the year must be considered, not total investments.	Click Here	Income-tax Act, 1961
Section 35	ZF Commercial Vehicle Control Systems India Ltd. v. DCIT	Capital expenditure deduction under Section 35(1)(iv) cannot be denied for lack of Form 3CM (required only for s. 35(2AB)), and opting for Section 115BAA does not bar it.	Click Here	Income-tax Act, 1961
Section 36	Seaview Developers (P.) Ltd. v. DCIT	Interest on capital borrowed to fund a court-approved capital reduction is deductible as a revenue business expenditure incurred out of commercial expediency.	Click Here	Income-tax Act, 1961
Section 36	Seaview Developers (P.) Ltd. v. DCIT	Where CCDs represent debt until conversion and the genuineness of foreign funds is established, interest paid on such CCDs is allowable under Section 36.	Click Here	Income-tax Act, 1961
Section 36(1)(va)	ACIT v. Zydus Lifesciences Ltd.	Deletion of duplicate disallowance upheld where the assessee had already suo motu disallowed delayed employee PF/ESI contributions and the AO disallowed it again.	Click Here	Income-tax Act, 1961
Section 37	Seaview Developers (P.) Ltd. v. DCIT	Property management fees paid on grounds of commercial expediency to a distinct non-related entity offering the receipts to tax cannot be disallowed.	Click Here	Income-tax Act, 1961
Section 56	Dhartivarsha Estate Holders (P.) Ltd. v. ITO	Section 56(2)(x) cannot be applied to land purchased under pre-2017 agreements where stamp duty value rose solely due to agricultural conversion at assessee’s own cost.	Click Here	Income-tax Act, 1961
Section 68	PCIT, Central v. Patanjali Ayurved Ltd.	A common Tribunal order disposing of seven appeals with procedural defects, differing dates, and no reasoning suffers from non-application of mind; set aside for fresh adjudication.	Click Here	Income-tax Act, 1961
Section 69A	ACIT v. Zydus Lifesciences Ltd.	Addition of Japanese Yen receipts as unexplained money is invalid when fully accounted for from a foreign subsidiary and offered to tax in the return.	Click Here	Income-tax Act, 1961
Section 69A / 153C	Necklace Diamond v. ITO	Reassessment based on third-party search material must follow Section 153C rather than Section 147/148; pre-31.03.2021 searches cannot trigger Section 148 notices.	Click Here	Income-tax Act, 1961
Section 80JJAA	JCIT (OSD) v. Prompt Personnel (P.) Ltd.	Manpower supply agencies employing workers directly on their payroll, paying wages via banking channels, and complying with labor laws qualify for Section 80JJAA deduction.	Click Here	Income-tax Act, 1961
Section 80P	Alaknanda Coop. Group Housing Society Ltd. v. CCIT	A 34-day delay in filing return due to delayed audit report should be condoned per CBDT Circular No. 13/2023 to evaluate Section 80P deduction on merits.	Click Here	Income-tax Act, 1961
Section 91	Hindustan Zinc Ltd. v. CIT	A settlement under Kar Vivad Samadhan Scheme (KVSS) is final and conclusive; tax refund from brought-forward losses cannot be granted if it reopens settled tax demand.	Click Here	Finance (No. 2) Act, 1998
Section 92C	ZF Commercial Vehicle Control Systems India Ltd. v. DCIT	No TP adjustment is warranted for notional interest on receivables from AEs when the assessee is an entirely debt-free company incurring no borrowing costs.	Click Here	Income-tax Act, 1961
Section 92C	ZF Commercial Vehicle Control Systems India Ltd. v. DCIT	Where overall transaction margins are accepted at arm’s length under TNMM, the TPO cannot isolate and benchmark integral centralized IT support fees at Nil.	Click Here	Income-tax Act, 1961
Section 115QA	Seaview Developers (P.) Ltd. v. DCIT	High Court-approved capital reduction under Companies Act is distinct from a share buy-back; where DDT was paid under Section 115-O, Section 115QA cannot be levied.	Click Here	Income-tax Act, 1961
Section 148	J J Foods (P.) Ltd. v. DCIT	Curtailing the Section 148A(b) reply period from the statutory 30 days to 15 days and ignoring the uploaded reply violates natural justice, voiding the reassessment order.	Click Here	Income-tax Act, 1961
Section 149	Sunil Bhalla v. DCIT	Adjournment periods sought by an assessee who fails to reply by the deferred date are excluded when calculating the limitation period for issuing notices under Section 148.	Click Here	Income-tax Act, 1961
Section 188A	S. Venkataramanan v. PCIT	Service of recovery notices on the firm is sufficient when proceeding against firm assets; individual partners require separate personal service only when personal assets are targeted.	Click Here	Income-tax Act, 1961
Section 222	S. Venkataramanan v. PCIT	Auction sales yielding amounts higher than guideline values cannot be vitiated over reserve price revisions in the absence of evidence showing sale below fair market value.	Click Here	Income-tax Act, 1961
Section 222	S. Venkataramanan v. PCIT	An initial auction attempt extends the limitation period under Rule 68B by one year; amended limitation periods apply to all cases where the original period was subsisting.	Click Here	Income-tax Act, 1961
Section 222	S. Venkataramanan v. PCIT	An auction sale under tax recovery proceedings cannot be invalidated simply because the successful bidder arranged demand drafts through a third party’s bank account.	Click Here	Income-tax Act, 1961
Section 234A	Pavithra Sugichandran v. DCIT	Where return was submitted within SC-extended COVID-19 deadlines, e-verification relates back to the filing date, rendering interest under Section 234A non-chargeable.	Click Here	Income-tax Act, 1961
Section 244A	Voltas Ltd. v. ACIT	Assessee is entitled by operation of law to additional 3% p.a. interest under Section 244A(1A) on refunds arising from Section 250 appellate orders if unadjusted or unwithheld.	Click Here	Income-tax Act, 1961
Section 244A	Voltas Ltd. v. ACIT	Section 244A(2) cannot deny refund interest under Section 244A(1)(a) when tax relief arises from an appellate order and no delay is attributable to the taxpayer.	Click Here	Income-tax Act, 1961
Section 253	Paradise Food Court (P.) Ltd. v. DCIT	A writ petition filed after an unexcused 5-year delay is barred by laches when the alternative statutory appeal remedy before the ITAT was bypassed.	Click Here	Income-tax Act, 1961
Section 271AAB	Rekha Goyal v. ACIT	Gross profit estimation on stock shortages does not qualify as “undisclosed income” represented by seized money, bullion, or entries; penalty under Section 271AAB is unsustainable.	Click Here	Income-tax Act, 1961
Section 271AAB	Rohan M Thakkar v. DCIT, Central	Undisclosed jewellery admitted during a search, declared in a revised return, and accepted without dispute attracts penalty at 10% under clause (a), not 30% under clause (c).	Click Here	Income-tax Act, 1961
Section 271AAB	Rohan M Thakkar v. DCIT, Central	Unreconciled jewellery not reflected in wealth tax returns or books constitutes “undisclosed income” under the Explanation to Section 271AAB.	Click Here	Income-tax Act, 1961
Section 271E	ACIT Central Circle v. Hari Mohan Dangayach	Penalty proceedings under Section 271E are invalid and liable to be quashed if no satisfaction was recorded by the Assessing Officer during reassessment proceedings.	Click Here	Income-tax Act, 1961