IMPORTANT INCOME TAX CASE LAWS 03.02.2026
| Section | Case Law | Core Ruling & Strategic Summary | Citation |
| S. 11 / 11(3) | AWARE (Hyderabad Trib.) | [Accumulation Audit] Deletion of an addition u/s 11(3) is invalid if the appellate authority fails to verify the actual utilization of brought-forward accumulated funds (₹1.24 Cr). | Click Here |
| S. 12AB / 80G | Kush Innovative Foundation | [Registration Proof] The Tribunal cannot direct the grant of regular registration without recording specific findings on the genuineness of activities and statutory compliance. | Click Here |
| S. 37(1) | Coastal Energy (P.) Ltd. | [New Evidence] Claims regarding “coal shortages and quality cuts” in AE transactions require fresh verification if additional documentary evidence is produced at the Tribunal stage. | Click Here |
| S. 44 / Rule 5 | National Insurance Co. | [Insurance Profits] General disallowance u/s 37(1) for management expenses exceeding IRDA limits is not applicable to insurance companies, as their profits are governed by specialized Rule 5. | Click Here |
| S. 80-IA / 147 | NTPC Ltd. (Delhi HC) | [Audit Objection] Reassessment initiated solely based on an audit party’s objection (without new facts) on issues already examined in the original assessment is an invalid “Change of Opinion.” | Click Here |
| S. 92C (TP) | Coastal Energy (P.) Ltd. | [Credit Notes] Purchase price adjustments based on AE credit notes/discounts must be verified against sworn affidavits to determine the correct Arm’s Length Price. | Click Here |
| S. 170A | Bajaj Electricals Ltd. | [Business Reorg] Once a modified return is filed post-reorganization (Amalgamation/Merger) and an assessment is passed, the AO cannot issue fresh notices to reassess that same return. | Click Here |
| S. 199 | Coastal Energy (P.) Ltd. | [TDS Credit] If TDS credit is acknowledged in the Draft Assessment Order, the AO is legally bound to grant it in the Final Assessment Order, even if the DRP is silent. | Click Here |
| S. 226(3) | Manjulaben Mafatlal Shah | [Recovery Limits] The Revenue cannot attach the bank account of a director’s spouse to recover a company’s tax dues solely on the basis of a marital relationship. | Click Here |
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