Category Archives: Income Tax

INCOME TAX CASE LAWS 07.07.2026

By | July 9, 2026

INCOME TAX CASE LAWS 07.07.2026 Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 1961 Section 2(14) Sundaramahalingam Narayanan v. Income-tax Officer Click Here No capital gains are chargeable if the Revenue fails to prove that the agricultural land sold falls within a municipality covered by a valid notification under Section 2(14)(iii)(b). Income-tax… Read More »

Condonation of delay is justified when non-service of orders prevents timely filing of appeals.

By | July 9, 2026

Condonation of delay is justified when non-service of orders prevents timely filing of appeals. Issue Whether the Commissioner of Income-tax (Appeals) [CIT(A)] was legally justified in dismissing the assessee’s quantum and penalty appeals in limine (at the threshold) due to delays of 1,486 and 1,181 days, without evaluating the merits or providing an opportunity to… Read More »

Extended reassessment is invalid if the quantified escaped income is below fifty lakh rupees.

By | July 9, 2026

Extended reassessment is invalid if the quantified escaped income is below fifty lakh rupees. Issue Whether a reassessment notice issued under section 148 after the standard three-year limitation period is legally sustainable when the Assessing Officer’s own order quantifies the total alleged escaped income at Rs. 42.82 lakhs, which falls below the statutory threshold of… Read More »

An order under section 148A(b) cannot stand if the Assessing Officer fails to consider the assessee’s reply and supporting materials.

By | July 9, 2026

An order under section 148A(b) cannot stand if the Assessing Officer fails to consider the assessee’s reply and supporting materials. Issue Whether an order passed under section 148A(d) and the consequential reassessment notice issued under section 148 can be legally sustained when the Assessing Officer completely fails to consider the assessee’s detailed replies and supporting… Read More »

Unrecorded warranty receivables from an AE constitute an asset, validating extended reassessment and special audit.

By | July 9, 2026

Unrecorded warranty receivables from an AE constitute an asset, validating extended reassessment and special audit. Issue Whether unrecorded contractual receivables from an Associated Enterprise (AE) for warranty reimbursements constitute an “asset” under Section 153A, allowing the extended 10-year reassessment notice window under Section 149(1)(b). Whether an extended reassessment notice can be sustained if the recorded… Read More »

Cash deposits from agricultural land sale require factual verification and matter is remanded for de novo adjudication.

By | July 9, 2026

Cash deposits from agricultural land sale require factual verification and matter is remanded for de novo adjudication. Issue Whether the addition of cash deposits worth Rs. 10.05 lakhs as unexplained money under section 69A of the Income-tax Act, 1961 is legally sustainable when the assessee submits documentary evidence proving the funds arose from an exempt… Read More »

On-money from an incomplete project cannot be taxed under the project completion method via revisionary powers.

By | July 9, 2026

On-money from an incomplete project cannot be taxed under the project completion method via revisionary powers. Issue Whether the Principal Commissioner of Income-tax (PCIT) can validly invoke revisionary powers under section 263 to tax an on-money receipt of Rs. 7.96 crore in the current assessment year, when the assessee follows the undisputed project completion method… Read More »

Sale proceeds from undisputed prior-year unlisted investments cannot be treated as unexplained cash credits.

By | July 9, 2026

Sale proceeds from undisputed prior-year unlisted investments cannot be treated as unexplained cash credits. Issue Whether the sale proceeds from the disposal of unlisted equity investments, which originated in unchecked prior years, can be treated as unexplained cash credits under section 68, and whether an ad hoc addition for commission expenses can be made under… Read More »

No section 68 addition is sustainable for an alleged cash loan without any credit entry in the assessee’s books.

By | July 9, 2026

No section 68 addition is sustainable for an alleged cash loan without any credit entry in the assessee’s books. Issue Whether an addition under section 68 of the Income-tax Act, 1961 can be legally sustained when there is no credit entry in the assessee’s books of account, and the addition is based entirely on a… Read More »

Departure in trading patterns alone during demonetization cannot justify a section 68 addition without rejecting the books of account.

By | July 9, 2026

Departure in trading patterns alone during demonetization cannot justify a section 68 addition without rejecting the books of account. Issue Whether a sudden surge or change in trading patterns during the demonetization period can by itself justify an addition of cash deposits as unexplained cash credit under section 68 of the Income-tax Act, 1961, when… Read More »