| Tribunals Reforms Act |
Legislative Update |
Tribunals Reforms Bill, 2026 |
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The Lok Sabha passed the Tribunals Reforms Bill, 2026, repealing the 2021 Act to set up an independent National Tribunals Commission overseeing appointments and service conditions across tribunals. |
| Prohibition of Benami Property Transactions Act, 1988 |
Section 2 |
Initiating Officer & ACIT (Benami Prohibition) v. Parshvanath Comtrade LLP |
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Held to be a benami transaction where the transferee paid only nominal upfront consideration for ₹100 crore shares, lacked capacity for the balance, relied on share dividends to pay, and seller retained a lien. |
| Income-tax Act, 1961 |
Section 12A |
Madhya Pradesh Jesuits v. State of Chhattisgarh |
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Municipal property tax exemption was denied and demand notice upheld after the assessee submitted a Section 12A registration certificate belonging to a different institution instead of its own. |
| Income-tax Act, 1961 |
Section 41(1) |
Deputy Commissioner of Income-tax v. State Bank of India |
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Write-back of provision for employee benefits is taxable only if a corresponding deduction was allowed in prior years; taxability must reflect earlier appellate orders to prevent double taxation. |
| Income-tax Act, 1961 |
Section 45 |
Giju Purapadathil Mathai v. Commissioner of Income-tax |
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Capital gains liability arises on auction/distress sale of mortgaged property by a bank even if entire proceeds settled third-party debt and no funds reached the assessee; gain is computed using statutory indexation. |
| Income-tax Act, 1961 |
Section 50C |
Kanubhai Purshottam Merchant v. Income-tax Officer |
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Section 50C cannot be invoked based solely on stamp duty valuation when the registered instrument is a tenancy agreement and no transfer of ownership or extra consideration is established. |
| Income-tax Act, 1961 |
Section 68 |
Agarwal Industries (P.) Ltd. v. DCIT |
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Deletion of Section 68 additions upheld as the assessee discharged its onus by proving credits came via account-payee cheques with proper documentation, including loan repayments. |
| Income-tax Act, 1961 |
Section 68 |
Deputy Commissioner of Income-tax v. Falcon Bus Lines (P.) Ltd. |
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Rejection of Section 68 addition; AO cannot make additions solely based on an uncorroborated survey statement when surrendered income was duly recorded in books and disclosed in the ITR. |
| Income-tax Act, 1961 |
Section 69 |
Mahesh Chandra Sharma v. ACIT |
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Additions under Section 69 deleted as impounded Tally credit balances reflected trust funds spent on behalf of the trust, with no evidence establishing unexplained cash loans from personal sources. |
| Income-tax Act, 1961 |
Section 69A |
Mahesh Chandra Sharma v. ACIT |
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Confirmed Section 69A addition for a ₹2 lakh cash loan as the lender’s creditworthiness was unproven and the story of accumulating cash via periodic withdrawals/redeposits was contrary to human probabilities. |
| Income-tax Act, 1961 |
Section 147 |
Kalyanasundaram Swaminathan v. Deputy Commissioner of Income-tax |
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As per Explanation 3 to Section 147, reassessment additions or disallowances are not restricted to reasons recorded for reopening and can encompass any other issue arising during reassessment. |
| Income-tax Act, 1961 |
Section 147 |
Roy Kurian v. Principal Commissioner of Income-tax |
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Rejection of witness statements on agricultural income claims on grounds of time expiry was unjustified when no formal order rejecting the extension request had been passed by the AO. |
| Income-tax Act, 1961 |
Section 147 |
Roy Kurian v. Principal Commissioner of Income-tax |
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Reassessment and penalty orders quashed for violation of natural justice as AO relied on official agricultural reports without giving the assessee an opportunity to cross-examine those officers. |
| Income-tax Act, 1961 |
Section 80P |
Aditya Vivdhoddeshagala Sahakara Sangha Niyamita v. Income-tax Officer |
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Interest income earned by a Souharda credit co-operative society from depositing idle/surplus funds in banks is eligible for deduction under Section 80P(2)(a)(i). |
| Income-tax Act, 1961 |
Section 80P / 139(1) |
Aditya Vivdhoddeshagala Sahakara Sangha Niyamita v. Income-tax Officer |
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Deduction under Section 80P claimed in a return filed under Section 148 cannot be denied for delayed filing; 6th proviso to Section 139(1) is inapplicable and Section 80A(5) requires only a valid return. |
| Income-tax Act, 1961 |
Section 143(2) / 147 |
Kalyanasundaram Swaminathan v. Deputy Commissioner of Income-tax |
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Issuance of Section 143(2) notice was legally impossible where the statutory deadline for completing the reassessment order under Section 147 read with Section 153 expired prior to that date. |
| Income-tax Act, 1961 |
Section 153C |
Bipinbhai Maganbhai Virani v. Income-tax Officer |
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Where documents belonging to an assessee are seized during a search on a third party, assessment must be initiated under Section 153C; reopening under Section 147 is without jurisdiction. |
| Income-tax Act, 1961 |
Section 234D |
Deputy Commissioner of Income-tax v. State Bank of India |
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Section 234D interest requires fresh computation post-appellate orders; if no excess refund demand remains after ITAT order effect, no interest under Section 234D is chargeable. |
| Income-tax Act, 1961 |
Section 244A |
Deputy Commissioner of Income-tax v. State Bank of India |
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While computing Section 244A interest, refunds already granted must be adjusted first against the interest component and only thereafter against principal tax. |
| Income-tax Act, 1961 |
Section 260A |
Principal Commissioner of Income-tax v. Jajodia Finance Ltd. |
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ITAT order deleting bogus share loss addition was set aside as perverse for relying on a statement retraction made two years post-admission and post-assessment without evidentiary backing. |
| Income-tax Act, 1961 |
Section 270A |
Ishwar Chand Agro (P.) Ltd. v. Deputy Commissioner of Income Tax |
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Section 270A penalty quashed as invalid because the AO initiated proceedings for under-reporting due to misreporting, but levied penalty for under-reporting without citing specific sub-clauses. |