IMPORTANT INCOME TAX CASE LAWS 08.02.2026

Relevant Section	Case Law Title	Core Ruling / Summary	Citation
Section 9	Booking.Com B.V. v. ACIT	An online accommodation platform hosted abroad, earning commission on a P2P basis without local assets or agents, does not have a Fixed Place or DAPE in India.	Click Here
Section 10(35)	Mukundbhai M. Patel v. ACIT	Reopening based merely on a survey of a mutual fund house, without evidence of the assessee’s involvement in sham transactions, is without jurisdiction.	Click Here
Section 14A	Tata Chemicals Ltd. v. DCIT	Disallowance u/s 14A cannot exceed exempt income. Rule 8D(2)(iii) recomputation must only consider investments that actually yielded exempt income.	Click Here
Section 14A / 115JB	DCIT v. JSW Energy Ltd.	Mathematical disallowance under Section 14A cannot be added back to “Book Profits” for MAT computation under Section 115JB.	Click Here
Section 32	DCIT v. JSW Energy Ltd.	Depreciation is disallowed on capitalized payments to a contractor where no actual work was done and the contractor admitted to providing accommodation entries.	Click Here
Section 35	Tata Chemicals Ltd. v. DCIT	Mere approval of an in-house R&D facility is just a threshold; the AO must verify the nexus of each specific expenditure with scientific research.	Click Here
Section 36(1)(iii)	Tata Chemicals Ltd. v. DCIT	Interest on funds borrowed to acquire controlling interest in overseas subsidiaries (not business assets) is not allowable as business expenditure.	Click Here
Section 37(1)	Schindler India (P.) Ltd v. DCIT	If international transactions are covered by a binding unilateral APA, the AO cannot disallow them u/s 37(1) by questioning “need” or “benefit.”	Click Here
Section 43B	Tata Chemicals Ltd. v. DCIT	Provisions for post-retirement medical benefits based on actuarial valuation are not covered by Section 43B but require factual verification of liability.	Click Here
Section 45	Popatrao D. Suryawanshi v. ITO	In a JDA, capital gains are computed using the market value at the time of possession (Occupancy Certificate) as the cost of acquisition for the owner.	Click Here
Section 54	Sanjay Gopaldas Bajaj v. ITO	Assessees can claim Section 54 deduction in a return filed in response to a Section 148 notice, even if no original return was filed u/s 139(1).	Click Here
Section 61 / 63	ITO v. Arcil Retail Loan Portfolio	A securitisation trust under SARFAESI is a revocable trust; income is taxable in the hands of receipt holders, not the trust/AOP.	Click Here
Section 68 / 69A	Anshu Sahai (HUF) v. ACIT	Additions based solely on a third-party Excel sheet or diary notings, without corroborative evidence or a cash trail, cannot be sustained.	Click Here
Section 142(2A)	Sanjay Nathalal Shah v. ACIT	A Special Audit order issued without a Document Identification Number (DIN) in the approval process is invalid and non-est in law.	Click Here
Section 199	Hasbro SA v. DCIT	TDS credit should be allowed in the year income is offered, even if the TDS reflects in the 26AS of the next year, provided no double claim is made.	Click Here
Section 270AA	Amalgam Steel (P) Ltd v. ACIT	Rejection of a penalty immunity application without a reasoned order or considering the assessee’s plea is a violation of natural justice.	Click Here

For More :- Read IMPORTANT INCOME TAX CASE LAWS 07.02.2026