INCOME TAX CASE LAWS 02.11.2026
Income-Tax Case Law Summary
| Relevant Act | Section | Case Law Title | Citation | Brief Summary |
| Income-tax Act, 1961 | Section 14A | DCIT Circle 3(4) v. Asian Paints Ltd. | Click Here | Additional disallowance made by the AO under Rule 8D over and above the assessee’s suo motu disallowance without recording proper satisfaction was held unsustainable. |
| Income-tax Act, 1961 | Section 36(1)(vii) | DCIT Circle 3(4) v. Asian Paints Ltd. | Click Here | Deduction for provision/write-off of doubtful debts is allowable under Section 36 and is not required to be added back while computing book profit under Section 115JB. |
| Income-tax Act, 1961 | Section 37(1) | DCIT Circle 3(4) v. Asian Paints Ltd. | Click Here | Expenditure incurred on ‘Colour Idea Stores’ for business promotion and sales was revenue in nature, and AO’s disallowance treating it as capital expenditure was unjustified. |
| Income-tax Act, 1961 | Section 37(1) | DCIT Circle 3(4) v. Asian Paints Ltd. | Click Here | Expenses on sales-promotion trip schemes for dealers (principal-to-principal basis) constituted allowable business promotion expenditure and could not be disallowed as commission or leisure packages. |
| Income-tax Act, 1961 | Section 68 | Principal Commissioner of Income-tax, (Central) v. Purushottam Lal Soni | Click Here | Restricting taxable income to 8% on account of presumed accommodation-entry business was held legally impermissible when unexplained cash payments, receipts, and loans found during search were not substantiated. |
| Income-tax Act, 1961 | Section 69A | Samir Arvindbhai Shah v. Assistant Commissioner of Income-tax | Click Here | Reassessment proceedings initiated on allegations of accounting manipulation to inflate surplus were quashed as no material established that the assessee knowingly participated in sham transactions. |
| Income-tax Act, 1961 | Section 69A | Girishkumar Parahladbhai Patel v. Assistant Commissioner of Income-tax | Click Here | A pre-dated entry in a broker’s register showing prevailing market rates (not an executed transaction) could not justify an on-money addition; Section 148 notice was quashed. |
| Income-tax Act, 1961 | Section 80G | Pawansut Dadrawa Sarkar Nyas v. Exemption Ward | Click Here | CIT(E)’s blanket rejection of Section 80G approval based solely on religious-cum-charitable objects without examining the 5% relaxation under Section 80G(5B) was invalid; matter remanded for fresh adjudication. |
| Income-tax Act, 1961 | Section 80G | Gillette India Ltd. v. PCIT | Click Here | Section 263 revision was unjustified where AO had duly examined and allowed Section 80G deduction for qualifying CSR donations under settled legal principles. |
| Income-tax Act, 1961 | Section 80G | Ntt Global Data Centers and Cloud Infrastructure India (P.) Ltd. v. Principal Commissioner of Income-tax | Click Here | Section 80G independently allows deduction for qualifying donations even if disallowed under Section 37(1) as CSR expenditure; Section 263 revision was held invalid. |
| Income-tax Act, 1961 | Section 80P | Poonam Chambers B Wing Commercial Premises Co-operative Society Ltd. v. Deputy Commissioner Income-tax | Click Here | Interest and dividend income earned by a co-operative premises society from investments/deposits with co-operative banks/societies qualifies for deduction under Section 80P(2)(d). |
| Income-tax Act, 1961 | Section 80P | Poonam Chambers B Wing Commercial Premises Co-operative Society Ltd. v. Deputy Commissioner Income-tax | Click Here | For AYs prior to 2021-22, Section 80P deduction could not be denied under Section 143(1)(a)(v) adjustments solely due to belated filing of returns, as the restriction applies prospectively from AY 2021-22. |
| Income-tax Act, 1961 | Section 80P | Poonam Chambers B Wing Commercial Premises Co-operative Society Ltd. v. Deputy Commissioner Income-tax | Click Here | Deduction under Section 80P(2)(d) cannot be denied at the CPC processing stage merely due to a column misclassification in the return if the nature of income and claim are clearly discernible. |
| Income-tax Act, 1961 | Section 90 | DCIT Circle 3(4) v. Asian Paints Ltd. | Click Here | Order granting Foreign Tax Credit (FTC) under Sections 90 and 91 was upheld as the revenue failed to demonstrate any distinguishing facts or law after verification of overseas expenditure. |
| Income-tax Act, 1961 | Section 148A | Bhupatbhai Rangildas Lakhwala v. Income-tax Officer | Click Here | A Section 148 notice and Section 148A(d) order were quashed because the AO provided only 5 days instead of the mandatory statutory period of 7 days under Section 148A(b). |
| Income-tax Act, 1961 | Section 153C | Devendra Anubhai Shah v. Assistant Commissioner of Income-tax | Click Here | Where a search was initiated prior to 01-04-2021, reopening notices under Sections 148A/148 were invalid as proceedings could only be conducted under Sections 153A/153C. |
| Income-tax Act, 1961 | Section 199 | Ramasamy Sundarraj v. Income-tax Officer | Click Here | Proportionate restriction of TDS under Rule 37BA does not apply to exempt agricultural land sales; full TDS credit under Section 199 is allowable even if exempt income is included in Form 26AS. |
| Income-tax Act, 1961 | Section 205 | Nirupama Nanda v. State of Odisha | Click Here | Direct demand cannot be raised on an employee where employers deducted TDS but failed to reflect/deposit it, provided the employee submits salary certificates and TDS details. |
| Income-tax Act, 1961 | Section 270A | BT Global Communications India (P.) Ltd v. Assessment Unit National Faceless Assessment Centre | Click Here | A penalty order passed under Section 270A while the quantum appeal against assessment was pending before the ITAT was held contrary to Section 275(1)(a) and quashed. |