IMPORTANT INCOME TAX CASE LAWS 19.12.2025
| Relevant Act | Section | Case Law Title | Brief Summary | Citation |
| Income-tax Act, 1961 | Section 4 (Capital vs. Revenue) | SRF Ltd. v. ACIT, LTU | Excise duty subsidies, interest subsidies under TUFS, and proceeds from the transfer of Certified Emission Reductions (Carbon Credits) are all held to be capital receipts and not chargeable to tax. | Click Here |
| Income-tax Act, 1961 | Section 11 / Form 10 | ACIT v. Chettinad Academy of Research and Education | A revised Form 10 (for accumulation of income) filed during search assessment relates back to the original form filed within time. The trust remains eligible for Section 11 exemption. | Click Here |
| Income-tax Act, 1961 | Section 12AB (Cancellation) | Rukmini Educational Charitable Trust v. PCIT | Cancellation of registration based on ‘borrowed satisfaction’ (relying solely on search findings without independent AO enquiry) is invalid. Also, the 2022 amendment to 12AB is not retrospective. | Click Here |
| Income-tax Act, 1961 | Section 32 (Depreciation) | SRF Ltd. / GBT India (P.) Ltd. | Goodwill acquired through slump sale or as a commercial right in a joint venture is an intangible asset eligible for depreciation under Section 32(1)(ii). | Click Here |
| Income-tax Act, 1961 | Section 35(2AB) (R&D) | SRF Ltd. v. ACIT, LTU | Weighted deduction for R&D cannot be limited to the amount in Form 3CL if the actual expenditure is higher and duly certified by auditors, provided the facility is DSIR-approved. | Click Here |
| Income-tax Act, 1961 | Section 36(1)(iii) (Interest) | R.K. Industries Unit- II LLP / Essae Suhagraja (P.) Ltd. | No disallowance of interest on borrowings is permitted if the assessee has sufficient interest-free funds (capital/reserves) to cover non-business advances or partner withdrawals. | Click Here |
| Income-tax Act, 1961 | Section 37(1) (Business Exp) | SRF Ltd. v. ACIT, LTU | Payment to a school located on business premises that provides preference to employees’ children is an allowable Staff Welfare Expenditure, not a non-deductible donation. | Click Here |
| Income-tax Act, 1961 | Section 68 (Cash Credit) | Ms. Lalitha Padmaja Thallapalli v. ITO | Cash returned by a goldsmith (labor charges) or received as advances for jewellery sales cannot be taxed as unexplained cash credit if the transactions are recorded and supported by invoices. | Click Here |
| Income-tax Act, 1961 | Section 92C (Transfer Pricing) | SRF Ltd. v. ACIT, LTU | Corporate Guarantee fee of 0.25% was held to be at Arm’s Length. Loans to subsidiaries benchmarked at LIBOR + basis points (backed by internal CUP/bank quotes) were also accepted. | Click Here |
| Income-tax Act, 1961 | Section 115JB (MAT) | SRF Ltd. v. ACIT, LTU | Section 14A disallowance cannot be added back when computing ‘Book Profits’ for MAT purposes. | Click Here |
| Income-tax Act, 1961 | Section 149 (Time Limit) | Veena Gupta v. DCIT / Dimple Sanjaykumar Shah v. ACIT | Reassessment notices for AY 2015-16 issued on or after 1-4-2021 must be dropped if they fall outside the survival period calculated under TOLA and the new regime. | Click Here |
| Income-tax Act, 1961 | Section 254 (Tribunal Order) | Accost Media LLP v. DCIT | The six-month limitation for filing a rectification application before the ITAT starts from the date the order is communicated to the assessee, not the date the order was passed. | Click Here |
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