IMPORTANT INCOME TAX CASE LAWS 20.02.2026

Relevant Section	Case Law Title	Core Ruling & Strategic Summary	Citation
Section 147 / 149	Sapphire Foods India Ltd. v. ACIT	[Audit Objection Shield] Reopening based solely on Audit Party objections regarding previously disclosed expenses is an impermissible “change of opinion.” Notice held time-barred as extended 6-year limit cannot apply to concluded assessments with full disclosure.	Click Here
Section 148 / 144B	ITO v. Vandana Malhotra	[Landmark SC] Reassessment notices issued manually by a Jurisdictional AO (JAO) instead of the National Faceless Assessment Centre (NFAC) are contrary to the Faceless Scheme and were set aside.	Click Here
Section 145 / 45	Milan Theatres (P.) Ltd. v. DCIT	[Accounting Consistency] Once conversion of an asset into stock-in-trade is accepted, FMV must be applied consistently to all units. Consistently followed “Project Completion Method” cannot be rejected without recording dissatisfaction u/s 145(3).	Click Here
Section 24(b)	Shantilal G. Muttha v. ACIT	[Let-out Property Relief] The ₹2 Lakh interest cap restriction (proviso to s. 24(b)) applies only to self-occupied property. For let-out properties, reopening based on “lack of lender’s certificate” for interest is invalid.	Click Here
Section 37(1)	Zuari Management Services Ltd.	[Commencement of Business] Statutory commencement (Certificate under Companies Act) suffices to claim revenue expenditure. Audit fees and commencement expenses are allowable even before actual operational revenue begins.	Click Here
Section 149(1)(b)	Akshay Deepak Talim v. ITO	[NRI Limitation] Reopening after 3 years is barred if the unexplained investment (net of documented housing loans) falls below the ₹50 Lakh threshold.	Click Here
Section 50C / 54F	Kishore Anand Shetty v. ACIT	[Revised Stamp Value] If a Supplementary Deed rectifies an original erroneous stamp valuation, the AO must adopt the revised value. Exemption u/s 54F stands if possession of a flat is received within 2 years.	Click Here
Section 56	Mange Ram v. PCIT	[Land Compensation] Interest u/s 28 of the Land Acquisition Act retains its capital character and is a non-taxable Capital Receipt, notwithstanding the 2009 Finance Act amendment.	Click Here
Section 68	Express Tradelink (P.) Ltd.	[Onus Discharged] Where assessee furnished PAN and banking trails for share capital, the AO cannot disregard audited balance sheets as “paper compliance” without contrary evidence.	Click Here
Section 12AB / 80G	Arulcheyal Kainkarrya Sabha	[Procedural Leniency] Rejection of registration for trust solely due to a delay in furnishing activity details is unsustainable; assessee must be given a fresh opportunity to submit documents on merits.	Click Here

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