IMPORTANT INCOME TAX CASE LAWS 21.01.2026
| Relevant Act | Section | Case Law Title | Brief Summary | Citation |
| Income-tax Act, 1961 | Section 192 / 194A | DCIT(TDS) v. Novartis Healthcare (P.) Ltd. | • ESOP: TDS liability arises at the time of exercise, not grant. • MSME Interest: Interest paid for delayed payments to MSMEs is penal/compensatory and not “interest” under Section 2(28A); hence, no TDS under Section 194A. | Click Here |
| Income-tax Act, 1961 | Section 69A / Evid. Act | DCIT v. Gopal Bhupendra Chudasama | [Digital Evidence Admissibility] Where an assessee (or their accountant) admits to the contents of seized digital data (on-money receipts) during a search and does not retract it, the Revenue can rely on it without a Section 65B certificate (Evidence Act). | Click Here |
| Income-tax Act, 1961 | Section 2(22)(e) | Radhika Roy v. DCIT | [Change of Opinion] If the AO examined a loan for “Deemed Dividend” (S. 2(22)(e)) in an earlier assessment and dropped it, reopening the assessment to tax the same loan as a “benefit” under Section 2(24)(iv) is a mere change of opinion and impermissible. | Click Here |
| Income-tax Act, 1961 | Section 68 | Rajnandani Projects (P.) Ltd. v. PCIT | [Tribunal’s Limit] The Tribunal cannot reverse a CIT(A) order deleting a Section 68 addition without demonstrating perversity or misreading of evidence, especially when the identity/source was proved via banking channels. | Click Here |
| Income-tax Act, 1961 | Section 70 | K2 Family (P.) Trust v. DCIT | [Utility Glitch Relief] If the online ITR utility prevents a valid Set-Off of Losses claim (Section 70), the Court directed the department to either fix the utility or accept a paper revised return. Technical glitches cannot defeat substantive rights. | Click Here |
| Income-tax Act, 1961 | Section 80G | Jeevan Rekha Trust v. CIT(Exemption) | [Outsourcing Charity] A trust that owns a hospital building but outsources operations to a third party for a percentage of turnover (effectively renting it out) is not conducting charitable activities itself. 80G approval denied. | Click Here |
| Income-tax Act, 1961 | Section 115JB | Antony Lara Enviro Solutions (P.) Ltd. v. PCIT | [Ind-AS Transition] Once the AO accepts the “Transition Amount” (on Ind-AS adoption) in the first year, the PCIT cannot invoke Section 263 in subsequent years to question the 1/5th deduction installment without new material. | Click Here |
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