IMPORTANT INCOME TAX CASE LAW 31.10.2025
| Section | Case Law Title | Brief Summary | Citation | Relevant Act |
| SECTION 2 | National Payments Corporation of India v. CIT (Exemptions) | Where an assessee charged nominal fees to recover costs for providing a platform for member banks, and the AO allowed section 11 exemption after specific inquiries, a revision under section 263 alleging violation of the proviso to section 2(15) (charitable purpose) was unjustified. | Click Here | Income-Tax Act, 1961 |
| SECTION 12AB | Sree Raja Rajeswari Educational Trust v. Commissioner of Income-tax, Exemptions | The CIT(E)’s rejection of a trust’s registration application under section 12AB based on allegations of commercial activities and non-charitable use of income was incorrect. The enquiry at the registration stage is limited to examining the genuineness of charitable objects and activities, which were found to be charitable, mandating the grant of registration. | Click Here | Income-Tax Act, 1961 |
| SECTION 32 | Assistant Commissioner of Income-tax v. Baxter Pharmaceuticals India (P.) Ltd. | SLP dismissed. Where an assessee acquired an injectable business on a slump sale basis and claimed depreciation on assets, they were entitled to claim depreciation based on a valuation report from an expert valuer who physically verified each asset, as the entire unit was purchased without individual asset values being assigned. | Click Here | Income-Tax Act, 1961 |
| SECTION 32 | Assistant Commissioner of Income-tax v. Baxter Pharmaceuticals India (P.) Ltd. | SLP dismissed. Since the issue of depreciation on goodwill (acquired via slump sale) was considered during the original regular assessment, the Assessing Officer did not have jurisdiction to reopen the assessment on the same issue. | Click Here | Income-Tax Act, 1961 |
| SECTION 35 | Pharmanza Herbal (P.) Ltd. v. Principal Commissioner of Income Tax | Post-Finance Act, 2015, the DSIR’s quantification of eligible R&D expenditure in Form 3CL is mandatory for claiming deduction under section 35(2AB). The AO must restrict the deduction to the approved and quantified extent, and failure to do so makes the assessment erroneous and prejudicial to the revenue. | Click Here | Income-Tax Act, 1961 |
| SECTION 43CA | Deputy Commissioner of Income-tax v. Amardeep Constructions | The 10 per cent tolerance limit introduced by the Finance Act, 2020, to section 43CA (full value of consideration for transfer of non-capital assets) is curative in nature and thus applicable retrospectively. | Click Here | Income-Tax Act, 1961 |
| SECTION 54F | Inamul Haq v. Income-tax Officer | An assessee who sold an immovable property in his name and invested all sale proceeds in the purchase of land in his minor son’s name and raised construction thereon was eligible for the section 54F exemption on the amount invested in the construction of the new house. | Click Here | Income-Tax Act, 1961 |
| SECTION 68 | Dipesh Parasmal Jain HUF v. Income-tax Officer | A reassessment based on an excise search indicating suppressed sales for FYs 2012-13 to 2014-15 was initiated for AY 2017-18. Since the AO was uncertain about the correct year of taxability, the reopening for AY 2017-18 was held invalid and quashed. | Click Here | Income-Tax Act, 1961 |
| SECTION 68 | KMG Wires (P.) Ltd. v. National Faceless Assessment Centre | Where the AO computed the peak balance of loans from directors without sharing the working or basis with the assessee and without issuing a show cause notice before making the addition, the assessment order was passed in breach of natural justice, requiring a remand for reconsideration. | Click Here | Income-Tax Act, 1961 |
| SECTION 68 | Bipinbhai v. Income-tax Officer | Where the AO was informed about the death of the assessee’s father, the impugned order and notice under section 148A(d) and section 148, respectively, issued against the deceased person were quashed and set aside. | Click Here | Income-Tax Act, 1961 |
| SECTION 69C | Nabeel Construction (P.) Ltd. v. Principal Commissioner of Income-tax | Disallowance of purchases and wages (recorded and paid through banking channels) in a labour-intensive construction business could not be re-characterised as unexplained expenditure under section 69C. Thus, the PCIT was not justified in invoking section 263 merely for preferring a different provision. | Click Here | Income-Tax Act, 1961 |
| SECTION 69C | KMG Wires (P.) Ltd. v. National Faceless Assessment Centre | Addition for purchases based on a supplier’s non-response to a notice was invalid when the supplier had already filed a reply confirming transactions and provided documents before assessment completion. Non-consideration of evidence was a violation of natural justice, requiring a remand. | Click Here | Income-Tax Act, 1961 |
| SECTION 115BAA | Maharishi Education Corporation P. Ltd. v. Income-tax Officer | For a company opting for taxation under section 115BAA, the applicable rate of tax for the total income, including Long Term Capital Gain, would be 22 per cent as per section 115BAA, and not 20 per cent under section 112. | Click Here | Income-Tax Act, 1961 |
| SECTION 145 | Deputy Commissioner of Income-tax v. Amardeep Constructions | An assessee firm consistently using the Project Completion Method (PCM) for revenue recognition in real estate, which was accepted in all preceding years, cannot be forced to use the Percentage Completion Method (PCM) by the AO without pointing out any change in factual or legal position. | Click Here | Income-Tax Act, 1961 |
| SECTION 147 | Inamul Haq v. Income-tax Officer | An assessment order passed under section 147 read with section 143(3) by an officer without proper jurisdiction (ITO, Ward-2) after proceedings were initiated by a different officer (ITO, Ward-3) was illegal and set aside. | Click Here | Income-Tax Act, 1961 |
| SECTION 244A | J & K Bank Ltd. v. Joint Commissioner Income-tax | Where interest on a refund was denied due to treating TDS certificates as defective, the matter was remanded for a fresh decision because the CBDT had issued a circular in 1989 regarding the waiver of mentioning challan details etc., an issue not thoroughly examined by the Commissioner (Appeals). | Click Here | Income-Tax Act, 1961 |
For More :- Read IMPORTANT INCOME TAX CASE LAWS 30.10.25