IMPORTANT INCOME TAX CASE LAWS 31.12.2025
| Relevant Act | Section | Case Law Title | Brief Summary | Citation |
| Income-tax Act, 1961 | Section 9 | Informatica Business Solutions (P.) Ltd. v. Jt. CIT | Secondment of employees to Indonesia where salary was routed through an Indonesian entity required fresh examination of the secondment agreement to determine the real employer and withholding tax obligations. | Click Here |
| Income-tax Act, 1961 | Section 10B | Halliburton Technology India (P.) Ltd. v. ACIT | Deduction under Section 10B cannot be disallowed in a Section 143(1) intimation due to a technical e-filing glitch, especially when the AO had examined and accepted the claim in regular assessment. | Click Here |
| Income-tax Act, 1961 | Section 11 | Dakuben Saremalji Sancheti (Nadol Charitable Trust) v. CIT (Exemptions) | Rejection of condonation for delay in filing Form 10B/10 solely based on CBDT’s three-year limitation was unjustified when the CIT(E) had already accepted COVID-19 as a valid reason for the belated return. | Click Here |
| Income-tax Act, 1961 | Section 28(iv) | Informatica Business Solutions (P.) Ltd. v. Jt. CIT | Reimbursement of realized forex loss on ECB repayment is not taxable as a benefit/perquisite under Section 28(iv) as it is in the shape of money and related to a capital transaction. | Click Here |
| Income-tax Act, 1961 | Section 69B / 263 | Vaksons Metaplast (P.) Ltd. v. PCIT | Initiation of revision proceedings under Section 263 on the issue of bogus purchases was bad in law because the same addition was already under challenge before the Commissioner (Appeals). | Click Here |
| Income-tax Act, 1961 | Section 69C | PCIT v. Mohit Pukhraj Kawdiya | Disallowance for bogus purchases was restricted to the profit element (6%) rather than 100% of the purchase value, as factual analysis showed only the profit margin was evaded. | Click Here |
| Income-tax Act, 1961 | Section 72A | CIT v. Eastman Exports Global Clothing Pvt Ltd. | Section 72A(4) (Demerger) does not impose a minimum period of existence condition unlike Section 72A(2) (Amalgamation). PCIT’s revision order treating a demerger as an amalgamation was incorrect. | Click Here |
| Income-tax Act, 1961 | Section 115BBE | ITO v. Mahendrakumar Bhagvandas | The higher tax rate under the amended Section 115BBE (effective 15-12-2016) is not retrospective. For periods prior to this date, the normal tax rate applies for calculating the tax effect for filing appeals. | Click Here |
| Income-tax Act, 1961 | Section 115JB | Bay Forge (P.) Ltd. v. ACIT | For MAT purposes (S. 115JB), the quantum of brought-forward loss is determined at the beginning of the year (1st April). A reduction of share capital during the year cannot retrospectively alter the opening loss position. | Click Here |
| Income-tax Act, 1961 | Section 148A | Gaurang Raghavjibhai Patel v. ITO | Reassessment order passed without granting adequate time to respond to the Section 148A(b) notice (alleging unexplained transactions) was quashed for violation of natural justice. | Click Here |
| Income-tax Act, 1961 | Section 245C | Khazana Jewellery (P.) Ltd. v. ITSC | Settlement Commission cannot partially accept a disclosure. If the manner of earning for a substantial portion (Rs. 80 Cr) is unsubstantiated, the application must be rejected in entirety. The Commission cannot convert it into deemed income under S. 69B/115BBE on its own. | Click Here |
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