| Income-tax Rules, 2026 |
Rules 160, 176 & 225; Forms 169 & 171 |
CBDT Notification |
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Notified the Income-tax (Fourth Amendment) Rules, 2026; revised Forms 169 and 171 for registration as a valuer and authorised practitioner, extending due dates to March 31, 2027, for those registered under ITA 1961. |
| Income-tax Act, 1961 |
Section 2 / Section 45(5A) |
Smt. Banaswadi Chinnappa Anitha v. DCIT |
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Execution of a registered JDA and PoA granting effective possession in March 2005 constitutes a transfer in FY 2004–05; capital gains are chargeable in AY 2005–06, as Section 45(5A) applies prospectively (post-2018). |
| Income-tax Act, 1961 |
Section 12A / Section 12A(1)(ac) |
Smt. Padmavati Vedprakash Charitable Trust v. CIT(E) |
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The statutory power to condone delay in filing Form No. 10AB under the proviso to section 12A(1)(ac) is independent of CBDT relaxation; rejection purely on limitation without examining charitable objects/cause is improper. |
| Income-tax Act, 1961 |
Section 22 |
Smt. Banaswadi Chinnappa Anitha v. DCIT |
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Addition towards alleged under-reported rental income from PG accommodation based solely on an uncorroborated loose sheet (dumb document) is unsustainable. |
| Income-tax Act, 1961 |
Section 22 |
Smt. Banaswadi Chinnappa Anitha v. DCIT |
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Rental receipts credited to a registered partnership firm formed by landowners and a developer cannot be taxed as undisclosed income in the hands of individual landowners where the firm’s legal status is recognized. |
| Income-tax Act, 1961 |
Section 36(1)(va) / Section 154 |
Dell International Services India (P.) Ltd. v. JCIT (LTU) & DCIT |
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Rectification under section 154 on the debatable issue of delayed employee contributions to PF/ESIC is impermissible; subsequent Supreme Court rulings do not make a debatable issue a mistake apparent from record for past rectifications. |
| Income-tax Act, 1961 |
Section 37(1) |
Trimble Information Technologies India (P.) Ltd. v. ITO |
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ESOP/ESPP discount cost reimbursed by an Indian subsidiary to its foreign parent represents employee compensation and is allowable as revenue expenditure under section 37(1). |
| Income-tax Act, 1961 |
Section 43(1) |
Secure Meters Ltd. v. ACIT |
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Claim to capitalize additional CST and interest demands into the actual cost of past capital assets for depreciation requires specific asset identification and WDV substantiation; remanded for factual determination. |
| Income-tax Act, 1961 |
Section 56(2)(vii)(b) |
Pushpendra Prakash Dharmawat v. AO |
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Mere registration of a redevelopment agreement without construction or handover of actual possession does not amount to ‘receipt’ of an immovable property for the invocation of section 56(2)(vii)(b). |
| Income-tax Act, 1961 |
Section 68 / Section 153C |
ACIT v. Sandhya Maulik Patel |
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SLP dismissed: Issuance of section 153C notices based on third-party search material without live nexus or incriminating material directly belonging/pertaining to the assessee is invalid and quashed. |
| Income-tax Act, 1961 |
Section 69A |
Veerakumar Traders v. ITO |
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Where regular bank deposits are accepted as business turnover, cash deposits during demonetization cannot be selectively isolated and taxed as unexplained money under section 69A without distinct contrary evidence. |
| Income-tax Act, 1961 |
Section 69B / Section 148 |
JCIT (OSD) v. Ramesh Kumar |
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For third-party search additions on alleged bogus purchases, only the embedded profit element constitutes escaped income; if this is under Rs. 50 lakh per year, reopening beyond three years is without jurisdiction. |
| Income-tax Act, 1961 |
Section 69B |
JCIT (OSD) v. Ramesh Kumar |
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Entire unaccounted purchase turnover cannot be treated as undisclosed investment under section 69B; additions must be restricted only to the embedded gross profit margin. |
| Income-tax Act, 1961 |
Section 69B / Section 147 |
JCIT (OSD) v. Ramesh Kumar |
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Assessing unaccounted purchases arising from a search on a third party directly under section 143(3) instead of initiating valid reassessment proceedings under section 147/148 renders the assessment order void ab initio. |
| Income-tax Act, 1961 |
Section 80GGC |
Prasad Siddharth Thorat v. ITO |
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Disallowance of deduction for political donation under section 80GGC upheld where the party was admitted to be engaged in running a bogus donation and cash-back commission racket. |
| Income-tax Act, 1961 |
Section 80-IA(9) / Section 80HHC |
Secure Meters Ltd. v. ACIT |
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Deductions allowed under Section 80-IA/80-IB need not be deducted from business profits prior to computing export relief under Section 80HHC(3); Section 80-IA(9) restricts aggregate claim limit, not step-wise computation. |
| Income-tax Act, 1961 |
Section 80-IB(10) / Section 245D |
ACIT v. Omaxe Ltd. |
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Reassessment proceedings cannot be initiated to disallow deductions granted by a final order of the Settlement Commission (ITSC); the Revenue’s remedy is strictly confined to section 245D(6) on grounds of fraud/misrepresentation. |
| Income-tax Act, 1961 |
Section 92C |
Trimble Information Technologies India (P.) Ltd. v. ITO |
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No notional interest can be imputed on outstanding trade receivables from AEs as a separate international transaction when the taxpayer is completely debt-free. |
| Income-tax Act, 1961 |
Section 145 / Section 68 |
Ganpat Pannalal v. NFAC, Delhi |
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Without rejecting audited books of account under section 145(1), an unexplained income addition cannot be sustained merely due to a difference between opening and closing cash or lack of original vouchers for opening cash. |
| Income-tax Act, 1961 |
Section 147 |
Papu Ram v. ACIT |
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Reassessment scope is not confined to initial reasons; information regarding ‘any issue’ of escaped income discovered from outside sources during proceedings can validly enlarge the assessment’s scope. |
| Income-tax Act, 1961 |
Section 147 |
Papu Ram v. ACIT |
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The Explanation to amended Section 147 validly expands the substantive power of the AO to assess any escaped income coming to notice subsequently and is constitutionally valid. |
| Income-tax Act, 1961 |
Section 147 / Section 153A |
Papu Ram v. ACIT |
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When search material emerges during pending reassessment, the Revenue has the discretion to either expand pending reassessment proceedings or initiate fresh search procedures; choosing either does not vitiate proceedings. |
| Income-tax Act, 1961 |
Section 147 / Section 148A |
Papu Ram v. ACIT |
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Under the amended Section 147 Explanation, if no addition is made on the original reopening issue, the AO can still assess other newly discovered escaped income issues without issuing fresh notices under section 148A. |
| Income-tax Act, 1961 |
Section 147 / Section 3 |
IFC IVF (P.) Ltd. v. JCIT |
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For a company incorporated on 01.01.2020 opting for an extended 15-month first financial year ending 31.03.2021 (AY 2021–22), separate reassessment notices for the initial 3 months under AY 2020–21 are invalid. |
| Income-tax Act, 1961 |
Section 270A |
Karnataka Sheep and Wool Development Corp. Ltd. v. ACIT |
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Delay in return filing caused by pending statutory audit in a state PSU is a bona fide explanation; where the return filed under section 148 is accepted without additions, penalty under section 270A cannot be levied. |
| Income-tax Act, 1961 |
Section 271(1)(c) |
PCIT v. Hasmukh I. Gandhi |
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SLP dismissed: Penalty notice issued on a cyclostyled template without striking off non-applicable limbs (‘concealed income’ vs. ‘inaccurate particulars’) is vague and invalidates the penalty order. |
