INCOME TAX CASE LAWS 21.10.2026

Here is the extracted and structured summary of the case laws in tabular format:

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Income-tax Act, 1961	Section 10(10AA)	Renu Moongia v. Income-tax Officer	Click here	Entire leave encashment of ₹9,04,669 received by a retired employee was exempt under Section 10(10AA), and the restriction to ₹3,00,000 was held to be untenable.
Income-tax Act, 1961	Section 14A	ECL Finance Ltd v. Deputy Commissioner of Income-tax	Click here	Interest disallowance under Rule 8D(2)(ii) was unwarranted as the NBFC’s own funds exceeded its investments; administrative disallowance under Rule 8D(2)(iii) was restricted to investments relevant to exempt income.
Income-tax Act, 1961	Section 23	ACIT v. Ace Associates	Click here	Addition of notional annual value under Section 23(5) was deleted for stock-in-trade commercial units that remained vacant, as the Revenue failed to prove they were complete, occupiable, and capable of being let.
Income-tax Act, 1961	Section 28(i)	Commissioner of Income-tax v. Bharat Overseas Bank Ltd.	Click here	Government Securities held by a bank as stock-in-trade are to be valued at market value or cost (whichever is lower), and any revaluation loss is allowable as a business loss.
Income-tax Act, 1961	Section 28(i)	Deputy Commissioner of Income-tax v. Vikaskumar Macwan	Click here	In Angadia business with large cash turnover, gross amounts cannot be assessed under Section 69A; only embedded commission estimated at 0.30% of total turnover is taxable under normal rates (not Section 115BBE).
Income-tax Act, 1961	Section 28(iv)	Principal Commissioner of Income-tax v. Amd India (P.) Ltd.	Click here	Fixed assets/equipment received free of cost on a returnable basis solely for software testing from an associated enterprise do not attract addition under Section 28(iv).
Income-tax Act, 1961	Section 32	MSRDC Sea Link Ltd. v. Principal Commissioner of Income-tax	Click here	An SPV acquiring existing tolling and O&M rights is entitled to depreciation on intangible assets under Section 32; CBDT Circular No. 9/2014 applies to infrastructure builders, rendering PCIT’s Section 263 order quashed.
Income-tax Act, 1961	Section 36(1)(vii)	Commissioner of Income-tax v. Bharat Overseas Bank Ltd.	Click here	Allowance for bad debts under Section 36(1)(vii) is independent of Section 36(1)(viia); the entire write-off of non-rural advances by a scheduled bank is fully deductible without adjustment.
Income-tax Act, 1961	Section 37(1)	ECL Finance Ltd v. Deputy Commissioner of Income-tax	Click here	Mark-to-market loss on open equity and currency derivative contracts held as stock-in-trade by an RBI-registered NBFC is an allowable deductible business loss, not a mere notional loss.
Income-tax Act, 1961	Section 40(a)(ia)	PVS Memorial Hospital Ltd. v. Commissioner of Income-tax	Click here	High Court held TDS under Section 194C instead of Section 194J fails Section 40(a)(ia); however, the Supreme Court dismissed the appeal without merits adjudication as the assessee’s liquidation was complete.
Income-tax Act, 1961	Section 54F	Vikram Singh v. Income-tax Officer	Click here	Exemption under Section 54F was allowed despite purchasing the residential flat 7 months & 18 days beyond the 2-year deadline, as the delay was covered under the COVID-19 limitation exclusion.
Income-tax Act, 1961	Section 64	Liya Acharya Minor v. Union of India	Click here	Reassessment proceedings initiated directly in a minor’s name were set aside, as the minor’s income was already clubbed with the father/natural guardian under Section 64(1A).
Income-tax Act, 1961	Section 68	ACIT v. Ace Associates	Click here	Omission to disclose closing stock in a prior year does not render the corresponding opening stock in the current year as unexplained cash credit under Section 68.
Income-tax Act, 1961	Section 69	ACIT v. Ace Associates	Click here	A security deposit received from HDFC Bank for leasing premises and recorded in books cannot be treated as an unexplained investment under Section 69 without supporting evidence.
Income-tax Act, 1961	Section 69A	Deputy Commissioner of Income-tax v. Vikaskumar Macwan	Click here	Cash transactions recorded in seized notebooks/mobiles reflecting gross client movements do not warrant a principal addition under Section 69A; only the embedded commission is taxable.
Income-tax Act, 1961	Section 80G	Shree Golalaria Digamer Jain Samaj Nyas v. Commissioner of Income-tax Exemption	Click here	Rejection of Section 80G approval without putting the trust on notice regarding alleged violations of Section 80G(5B) was set aside for de novo adjudication with an opportunity to rectify Form 10AB.
Income-tax Act, 1961	Section 80-IB	TTK Protective Devices Ltd. v Assistant Commissioner of Income-tax	Click here	Denial of Section 80-IB deduction for contraceptives in 1 out of 10 years was unjustified when the revenue consistently allowed it in other years and the items did not strictly fall under Eleventh Schedule exclusions.
Income-tax Act, 1961	Section 92BA	ECL Finance Ltd v. Deputy Commissioner of Income-tax	Click here	Since Section 92BA(i) was omitted by the Finance Act, 2017, TP adjustments for specified domestic transactions covered under that clause cannot legally survive.
Income-tax Act, 1961	Section 92C	Principal Commissioner of Income-tax v. Amd India (P.) Ltd.	Click here	Application of an upper turnover filter of ₹200 crores under TNMM was justified to exclude large entities when the assessee had a significantly lower turnover.
Income-tax Act, 1961	Section 92C	Principal Commissioner of Income-tax v. Amd India (P.) Ltd.	Click here	Provision for bad and doubtful debts must be treated as an operating expense when computing the profit margin / Profit Level Indicator (PLI) for ALP determination.
Income-tax Act, 1961	Section 92C	Principal Commissioner of Income-tax v. Amd India (P.) Ltd.	Click here	Computing the Profit Level Indicator (PLI) on a cash basis by excluding depreciation from operating costs while applying TNMM for ALP determination is legally permissible.
Income-tax Act, 1961	Section 96	EKGE Retail LLP v. Assistant Commissioner of Income-tax	Click here	Pre-bonus purchase and post-bonus sale of listed shares to create short-term capital loss to set off against slump sale gains does not constitute an Impermissible Avoidance Arrangement under Section 96.
Income-tax Act, 1961	Section 148	Assistant Commissioner of Income-tax v. Nareshkumar Kishanlal Saraf	Click here	SLP against quashing of Section 148 notices disposed of in terms of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70, directing AO to dispose of objections accordingly.
Income-tax Act, 1961	Section 149	Manoj Garg v. DCIT	Click here	Notice issued under Section 148 beyond the limitation period specified in Section 149 for AY 2016-17 was barred by limitation and quashed.
Income-tax Act, 1961	Section 149	Style Solutions (P.) Ltd. v. Assistant Commissioner of Income-tax, Central	Click here	Section 148 notice issued on 31.08.2024 for AY 2016-17 was quashed as it was issued post the expiry of the maximum 6-year limitation period on 31.03.2023.
Income-tax Act, 1961	Section 153D	Principal Commissioner of Income-tax v. Helios Exports Ltd.	Click here	SLP dismissed against quashing of Section 153A assessments where Section 153D approvals were granted en masse within 24 hours using identical wording without referencing draft orders.
Income-tax Act, 1961	Section 194J	PVS Memorial Hospital Ltd. v. Commissioner of Income-tax	Click here	High Court ruled payments between hospitals for professional services attract Section 194J (not 194C); SC dismissed appeal without merits adjudication due to the company’s complete liquidation.
Income-tax Act, 1961	Section 270A	Vachan Singh v. Deputy Commissioner of Income-tax	Click Here	Penalty levied at 200% for “misreporting” under Section 270A(8)/(9) without establishing statutory conditions cannot be post-facto converted or sustained as a 50% penalty for “under-reporting” under Section 270A(7).