INCOME TAX CASE LAWS 13.07.2026

Section	Case Law Title / Notification	Brief Summary	Citation	Relevant Act
Notification	F. NO. 225/73/2025-ITA-II, Dtd 08-07-2026	CBDT authorizes the DGIT (Systems) to upload foreign tax information received under the Automatic Exchange of Information (AEOI) framework directly to the Annual Information Statement (AIS) within specified timelines.	Click Here	Income-tax Act, 2025 / Income-tax Act, 1961
Section 9	Sasken Technologies Ltd. v. ACIT	Payments made to Forrester Research Ltd., UK, for a license to access its website and use branded materials constitute taxable “Royalty” under Section 9, justifying disallowance under Section 40(a)(i) for non-deduction of TDS.	$2026$ Click Here	Income-tax Act, 1961
Section 9	Sasken Technologies Ltd. v. ACIT	The matter regarding contract staffing payments made to a UK company was remanded to give the assessee an opportunity to furnish the scope of work to determine whether it was a case of mere manpower supply or technical software development.	$2026$ Click Here	Income-tax Act, 1961
Section 9	Sasken Technologies Ltd. v. ACIT	Payments made to non-resident contractors via a US branch for onsite software development cannot be taxed as “Fees for Included Services” (FIS) in India if no technical knowledge or expertise was “made available” to the assessee.	$2026$ Click Here	Income-tax Act, 1961
Section 12AB	Akashdeep Education Trust v. ITO	Rejection of regular registration renewal solely on limitation grounds is unsustainable when the trust initially filed Form 10AB under an incorrect sub-clause but corrected it via a fresh form before the expiry of the provisional registration.	$2026$ Click Here	Income-tax Act, 1961
Section 13	CIT v. Aaspas Investment (P.) Ltd.	Penalty for concealment of chargeable interest cannot be levied in the absence of mala fide intention when the returns were filed in response to statutory notices and subsequently accepted without any additions.	$2026$ Click Here	Interest Tax Act, 1974
Section 14A	Sasken Technologies Ltd. v. ACIT	A disallowance under Section 14A read with Rule 8D is legally untenable and must be deleted if the Assessing Officer fails to record objective dissatisfaction regarding the assessee’s claims.	$2026$ Click Here	Income-tax Act, 1961
Section 37(1)	Reliance Retail Ltd. v. ACIT	Expenditure incurred to upgrade an existing e-commerce platform out of commercial necessity, without creating a new asset, is fully allowable as revenue expenditure.	$2026$ Click Here	Income-tax Act, 1961
Section 48	Prabhat Bhatia v. Circle, International Tax	A claim for the cost of improvement made by an NRI based on a registered valuer’s report for renovations done by the donor must be allowed if the AO rejects the estimate without referring the matter to the DVO.	$2026$ Click Here	Income-tax Act, 1961
Section 68	PCIT v. Jas Trading (P.) Ltd.	Reassessment is unjustified and invalid if it is based solely on a director’s statement that was formally retracted prior to the issuance of the Section 148 notice, especially when full reasons for reopening were not shared.	$2026$ Click Here	Income-tax Act, 1961
Section 69A	Satinder Govind Oberai v. ITO	A cash deposit during demonetization made by a salaried individual and explained as marriage gifts, past savings, and medical contingencies cannot be treated as unexplained unexplained money simply because the cash was retained for a few months.	$2026$ Click Here	Income-tax Act, 1961
Section 80C	Emdarapu Kumaraswamy v. ITO	The matter regarding Chapter VI-A deductions and house property losses was remanded to verify if the tax liability was duly discharged via an updated return, in which case the addition should be deleted.	$2026$ Click Here	Income-tax Act, 1961
Section 80G	Sasken Technologies Ltd. v. ACIT	Deductions under Section 80G cannot be denied for donations that form part of Corporate Social Responsibility (CSR) outlays, as the Act contains no express bar prohibiting such a claim.	$2026$ Click Here	Income-tax Act, 1961
Section 80G	Reliance Retail Ltd. v. ACIT	A retail company cannot be denied a Section 80G deduction on contributions simply because the expenditure qualifies as CSR expenditure under the Companies Act.	$2026$ Click Here	Income-tax Act, 1961
Section 80JJAA	Reliance Retail Ltd. v. ACIT	A deduction in respect of employment of new workmen cannot be denied merely because the supporting Form 10DA was filed belatedly.	$2026$ Click Here	Income-tax Act, 1961
Section 80JJAA	Ranstad India (P.) Ltd. v. ACIT	The AO was directed to re-verify and allow the deduction under Section 80JJAA by taking into consideration the enhanced gross total income assessed, rather than restricting it to the lower income originally declared.	$2026$ Click Here	Income-tax Act, 1961
Section 80P	ITO v. Yashomandir Sahkari Patpedhi Maryadit	Once a Section 263 order is quashed by the Tribunal, any consequential assessment order treating bank deposit interest as “Income from Other Sources” to deny the Section 80P(2)(d) deduction automatically loses its legal foundation.	$2026$ Click Here	Income-tax Act, 1961
Section 90	Reliance Retail Ltd. v. ACIT	A legitimate claim for Foreign Tax Credit (FTC) cannot be denied to an assessee merely due to a delay in filing Form No. 67 under Rule 128.	$2026$ Click Here	Income-tax Act, 1961
Section 92C	Ranstad India (P.) Ltd. v. ACIT	Where the TPO determined the ALP of global IT services as ‘nil’ due to a lack of evidence, the matter was remanded for fresh consideration as the assessee subsequently furnished the Master Service Agreement, invoices, and cost workings.	$2026$ Click Here	Income-tax Act, 1961
Section 92E	Posco Holdings Inc v. DCIT	No penalty under section 271AA is leviable for non-reporting of raw material sales in Form 3CEB if the transaction was done directly from abroad, had no effective nexus with the Indian Project Office/PE, and established a reasonable cause.	$2026$ Click Here	Income-tax Act, 1961
Section 115BB	Emdarapu Kumaraswamy v. ITO	For the purpose of taxing online gaming under Section 115BB, only net winnings or losses from the platform should be considered. Taxing gross winnings without setting off losses incurred on the same platform is erroneous.	$2026$ Click Here	Income-tax Act, 1961
Section 124	Gulshan Vohra v. ITO	When the initiation of reassessment is challenged on the ground that the Section 148 notice was issued by an officer lacking jurisdiction, the matter must be remanded to verify the correct jurisdictional officer from assessment records.	$2026$ Click Here	Income-tax Act, 1961
Section 148	Gulshan Vohra v. ITO	Proper and valid service of a statutory notice is a mandatory jurisdictional prerequisite. If service by affixation is challenged, the assessment must be set aside for fresh adjudication to verify compliance with all legal formalities.	$2026$ Click Here	Income-tax Act, 1961
Section 192	DCIT (TDS) v. Novartis Healthcare (P.) Ltd.	A taxable perquisite for ESOPs/ESBPs arises only upon the actual exercise of the option and allotment of shares. An employer cannot be treated as an assessee-in-default for non-deduction of TDS at the grant or accounting recognition stage.	$2026$ Click Here	Income-tax Act, 1961
Section 194A	DCIT (TDS) v. Novartis Healthcare (P.) Ltd.	Interest paid under the MSMED Act on delayed payments does not constitute interest on a debt or borrowed money under Section 2(28A). Since the company already disallowed the expense under Section 37(1), no TDS is deductible under Section 194A.	$2026$ Click Here	Income-tax Act, 1961
Section 194H	DCIT (TDS) v. Novartis Healthcare (P.) Ltd.	Trade margins retained by stockists in a principal-to-principal transaction are ordinary commercial trading discounts, not commission or brokerage. The pharmaceutical company is not liable to deduct tax under Section 194H.	$2026$ Click Here	Income-tax Act, 1961
Section 201	State Bank of India v. ITO	A bank is liable as an assessee-in-default with interest under Section 201 for failing to deduct TDS on Leave Fare Concession (LFC) travel reimbursements that included foreign travel legs, given that full travel itineraries were available.	$2026$ Click Here	Income-tax Act, 1961
Section 244A	Bedmutha Industries Ltd. v. ACIT	The Assessing Officer has no independent jurisdiction to decide on the exclusion of a period to deny interest on refunds under Section 244A(2) if no such determination has been passed by the competent authority.	$2026$ Click Here	Income-tax Act, 1961
Section 244A	Bedmutha Industries Ltd. v. ACIT	Interest under Section 244A is payable up to the actual date of refund, and no period can be excluded if the delay in releasing the refund arises out of administrative, systemic, or bank validation issues not attributable to the assessee.	$2026$ Click Here	Income-tax Act, 1961
Section 251	Posco Holdings Inc v. DCIT	The Commissioner (Appeals) cannot enhance a Section 271AA(1) penalty by introducing new international transactions that were never examined or covered by the Assessing Officer in the initial penalty proceedings.	$2026$ Click Here	Income-tax Act, 1961