IMPORTANT INCOME TAX UPDATE 05.12.2025

By | December 6, 2025

IMPORTANT INCOME TAX UPDATE 05.12.2025

SectionCase Law TitleBrief SummaryCitationRelevant Act
4Maruti Suzuki India Ltd. v. DCITSales tax incentives/subsidies received under a State scheme are treated as capital receipts, not taxable as revenue receipts under Section 28(iv).Click HereIncome-tax Act, 1961
9Maruti Suzuki India Ltd. v. DCITPayments for imports on FOB terms (title passed outside India) are not subject to withholding tax. PE/Profit attribution issues belong under Transfer Pricing, not withholding tax provisions.Click HereIncome-tax Act, 1961
14AMaruti Suzuki India Ltd. v. DCITDisallowance of interest is unwarranted if investments are made from surplus funds. Administrative cost disallowance is limited only to investments actually yielding exempt income.Click HereIncome-tax Act, 1961
35Maruti Suzuki India Ltd. v. DCITWeighted deduction for in-house R&D allowed despite minor procedural lapses (Form 3CL approval issues) since the facility was recognized under Form 3CM.Click HereIncome-tax Act, 1961
36(1)(va)Spectrum Talent Management v. ACITMatter restored to AO to verify if employee PF contributions were made within the due date including the grace period allowed by the PF Act.Click HereIncome-tax Act, 1961
37(1)Spectrum Talent Management v. ACITAd hoc disallowance of 10% on travel/telephone expenses deleted as no specific discrepancies were found in audited books.Click HereIncome-tax Act, 1961
37(1)Ocean Sparkle Ltd. v. DCITReassessment (Sec 263) set aside; allocation of expenses between Tonnage and Non-Tonnage divisions based on turnover ratio was correct. Irrecoverable advances are allowable as revenue deduction.Click HereIncome-tax Act, 1961
37(1)Maruti Suzuki India Ltd. v. DCITAd hoc disallowance of common facility expenses alleging benefit to subsidiaries is unsustainable without specific findings that expenses were not for the assessee’s business.Click HereIncome-tax Act, 1961
37(1)Maruti Suzuki India Ltd. v. DCITCSR expenditure incurred for brand promotion and community interface prior to 01.04.2015 is allowable as business expenditure.Click HereIncome-tax Act, 1961
37(1)Maruti Suzuki India Ltd. v. DCITYear-end provisions for price adjustments payable to suppliers (based on contracts) are accrued liabilities and allowable, not contingent.Click HereIncome-tax Act, 1961
37(1)Maruti Suzuki India Ltd. v. DCITRoyalty payments and R&D cess on royalty are revenue in nature and allowable as business expenditure.Click HereIncome-tax Act, 1961
37(1)ITO v. Govindam Agro Foods (P.) Ltd.Ad hoc 30% disallowance for lack of PAN/address deleted as assessee produced bills, vouchers, and ledgers establishing genuineness.Click HereIncome-tax Act, 1961
37(1)ITO v. Govindam Agro Foods (P.) Ltd.Provision for audit fees certified in audited accounts is allowable; addition for lack of further evidence is unjustified.Click HereIncome-tax Act, 1961
40A(3)ITO v. Govindam Agro Foods (P.) Ltd.Disallowance not warranted where payments exceeding limits were made through banking channels, not cash.Click Here
Income-tax Act, 1961
41(1)ITO v. Govindam Agro Foods (P.) Ltd.Section 41(1) cannot be invoked for cessation of liability on unsecured loans taken for capital purposes before the commencement of commercial activity.Click HereIncome-tax Act, 1961
43BMaruti Suzuki India Ltd. v. DCITStatutory duties (Excise, R&D cess, Customs) and MODVAT differences are allowable deductions under Sec 43B/145A.Click HereIncome-tax Act, 1961
43BMaruti Suzuki India Ltd. v. DCITMatter remanded to AO to verify claims regarding excise duty balances in RG 23A Part II and duty paid on consumed inputs.Click HereIncome-tax Act, 1961
45Maruti Suzuki India Ltd. v. DCITGains from surplus funds invested in mutual funds (treasury practice) are Capital Gains, not business income (CBDT Circular No. 6/2016 applies retrospectively).Click HereIncome-tax Act, 1961
54FDaulat Singh Haldea v. ITO100% exemption allowed where new house was purchased jointly with son (suffering from schizophrenia) for convenience; assessee paid the entire consideration.Click HereIncome-tax Act, 1961
68PCIT v. Surendra B. JiwrajkaAddition of LTCG as income under Sec 153A deleted as no incriminating material was found during search.Click HereIncome-tax Act, 1961
69AAdor Welding Ltd. v. DCITMatter regarding unaccounted sales from non-filer parties remitted to AO for verification of additional documents (invoices/e-way bills) filed during appeal.Click HereIncome-tax Act, 1961
92CMaruti Suzuki India Ltd. v. DCITWhere TNMM is applied at entity level and profit is at arm’s length, separate TP adjustment for royalty payment is unwarranted.Click HereIncome-tax Act, 1961
147Srinivasa Services v. Assessment UnitJurisdictional Assessing Officer (JAO) has no jurisdiction to initiate proceedings under Sec 148A/148 after the Faceless Scheme came into effect (29-3-2022).Click HereIncome-tax Act, 1961
148Khurshid Ahmad Dar v. ITOReassessment quashed as bad in law where notice lacked AO’s signature, did not follow amended 148A procedure, and was served late/improperly.Click HereIncome-tax Act, 1961
148ASooriya Hospital v. DCITNotice under Sec 148A invalid where it relied on prior year’s data rather than information pertaining to the relevant assessment year.Click HereIncome-tax Act, 1961
149Vishwa Realty Ltd. v. Assessment UnitReopening notice issued on 25-6-2021 for AY 2015-16 is invalid as TOLA extension does not apply.Click HereIncome-tax Act, 1961
149Sachin Panchal v. DCITFor searches after 31-3-2021, limitation period for Sec 148 notice aligns with Sec 153A period; reassessment covers 10 years for escaped income.Click HereIncome-tax Act, 1961
158BSurabhi Shelters (P.) Ltd. v. DCITRetracted statement of MD without incriminating material found during search cannot be the sole basis for block assessment addition.Click HereIncome-tax Act, 1961
269TSant Baba Sunder Singh Ji Can. Char. Trust v. CITPenalty under Sec 271E justified where the assessee trust repaid unsecured interest-free loans/advances in cash.Click HereIncome-tax Act, 1961
271(1)(c)Abdul Jabbar Jaheer Husain v. ITOPenalty for concealment deleted; mere disallowance of Sec 54F claim due to lack of some vouchers does not amount to furnishing inaccurate particulars.Click HereIncome-tax Act, 1961

For More :- Read IMPORTANT INCOME TAX CASE LAWS 04.12.2025