| Income-tax Act, 2025 |
Sec. 147 |
Notification No. 80/2026, Dated 10-07-2026 |
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CBDT exempts specified payments (interest, dividends, professional fees, commission, etc.) to 14 categories of eligible IFSC units from TDS. Relief applies for 20 consecutive tax years, effective retrospectively from April 1, 2026, subject to filing Form No. 1(N). |
| Income-tax Act, 2025 |
Sec. 258(1)(b) |
Notification No. 81/2026, Dated 10-07-2026 |
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CBDT permits sharing taxpayer information with the Principal Secretary, Cooperation, Marketing and Textile Dept., Govt. of Maharashtra, to identify eligible beneficiaries for the Punyashlok Ahilyadevi Holkar Farmer Loan Waiver Scheme, 2026. |
| Income-tax Act, 1961 |
CBDT Informant Rewards Guidelines, 2007 |
ABC v. Union of India |
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When the CBDT Full Board determines a final reward using a systematic methodology aligned with guidelines, the High Court will not interfere or modify the award unless manifest illegality or patent arbitrariness is demonstrated. |
| Income-tax Act, 1961 |
Sec. 2(47) / 50C |
Mahoharlal Jiwandas Sachani v. CIT (Appeals) NFAC |
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A 50-year lease of co-owned agricultural land to a family partnership firm without intent to permanently alienate rights outside the family does not constitute a “transfer” under Sec. 2(47). Consequently, capital gains computed via Sec. 50C are unsustainable. |
| Income-tax Act, 1961 |
Sec. 10(13A) |
Kuldeepkumar D. Kaura v. DCIT |
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HRA exemption cannot be denied merely because the employer paid the rent directly to the landlord and subsequently recovered it from the employee’s salary. |
| Income-tax Act, 1961 |
Sec. 12AB / 80G |
Keshavlal Vajechand Kapadia Charity Trust v. CIT (Exemptions) |
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Granting registration/approval subject to the outcome of a speculative future challenge before the Supreme Court is invalid. Efficacy of a grant must be based on the law prevailing on the date of the grant. |
| Income-tax Act, 1961 |
Sec. 32 / 148 |
DCIT v. Paypal India (P.) Ltd. |
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Reopening an assessment after 4 years to capitalize software expenses—when the issue was fully examined in the original scrutiny and no new tangible material exists—constitutes an impermissible change of opinion. Sec. 148 notice quashed. |
| Income-tax Act, 1961 |
Sec. 36(1)(iii) |
Kirloskar Electric Company Ltd. v. DCIT |
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Where an assessee possesses substantial interest-free funds that exceed its investments in subsidiaries/sister concerns, a presumption arises that investments were made out of interest-free funds. No interest disallowance is warranted. |
| Income-tax Act, 1961 |
Sec. 37(1) |
ICICI Securities Ltd. v. DCIT |
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Year-end provisions for brokerage/commission based on identifiable transactions and contractual rates for services already rendered are accrued business liabilities (not contingent), and are fully deductible under the mercantile system. |
| Income-tax Act, 1961 |
Sec. 37(1) |
Siemens Ltd. v. DCIT |
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Provisions for liquidated damages are allowable in principle. However, if historical trends show variation from actual crystallization, restricting the deduction to 50% is justified, provided adjustments are made later to avoid double taxation. |
| Income-tax Act, 1961 |
Sec. 37(1) |
Siemens Ltd. v. DCIT |
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Provisions for long service awards and post-retirement medical benefits based on actuarial valuations represent present values of accrued/ascertained liabilities for services already rendered, making them fully deductible. |
| Income-tax Act, 1961 |
Sec. 37(1) |
Siemens Ltd. v. DCIT |
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Warranty provisions based on contractual obligations, past experience, and technical estimates are allowable in principle. Revenue may restrict allowability to 50% on grounds of reasonableness, with adjustments to prevent future double taxation. |
| Income-tax Act, 1961 |
Sec. 37(1) |
Siemens Ltd. v. DCIT |
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Real substance prevails over bookkeeping nomenclature. A genuine business purchase of accessories erroneously booked as “commission” remains fully deductible as a business expenditure. |
| Income-tax Act, 1961 |
Sec. 43B |
ICICI Securities Ltd. v. DCIT |
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When a bonus provision previously taxed under Sec. 43B is reversed in the current year due to cessation of liability, the reversal amount is deductible to avoid double taxation. |
| Income-tax Act, 1961 |
Sec. 45 / 28 |
Derby Clothing (P.) Ltd. v. ITO |
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Insurance compensation received for fire loss to stock/interiors cannot be taxed separately as business income under Sec. 28 if the net loss was already adjusted in the P&L Account, as it leads to double taxation. |
| Income-tax Act, 1961 |
Sec. 54 |
Mohd. Amin Esmail Fazlani v. ITO |
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Sec. 54 deduction cannot be denied merely because the new residential property was purchased jointly with the assessee’s wife, provided the entire sale proceeds were utilized for the acquisition. |
| Income-tax Act, 1961 |
Sec. 54F |
Anant Ramchandra Dhotre v. ITO |
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Reinvesting the entire consideration received from surrendering tenancy rights of an old municipal flat to acquire a new alternate accommodation under redevelopment qualifies for a full Sec. 54F deduction. |
| Income-tax Act, 1961 |
Sec. 56(2)(x) / 45 |
Anant Ramchandra Dhotre v. ITO |
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Receiving a larger alternate accommodation upon surrendering inherited tenancy rights under a redevelopment plan constitutes a transfer taxable under Capital Gains (Sec. 45 r.w.s. 48) and not “Income from Other Sources”. Thus, Sec. 56(2)(x) does not apply. |
| Income-tax Act, 1961 |
Sec. 69A |
Sengodan Govindarajan v. ITO |
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Out of demonetization cash deposits, where major portions are covered under PMGKY or taxed in earlier years, addition under Sec. 69A can only be sustained to the extent of the remaining truly unexplained amount. |
| Income-tax Act, 1961 |
Sec. 72 / 80 |
Trinity Opportunity Fund I v. AO – Int tax |
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If a loss return was filed within the due date and determined by the AO, an inadvertent reporting omission in a subsequent year’s return cannot defeat the substantive right to carry forward and set off business losses. |
| Income-tax Act, 1961 |
Sec. 80G |
ICICI Securities Ltd. v. DCIT |
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A Sec. 80G deduction cannot be denied to an approved institution merely because the donation also satisfies the company’s Corporate Social Responsibility (CSR) mandates, provided all statutory Sec. 80G rules are met. |
| Income-tax Act, 1961 |
Sec. 87A / 111A / 115BAC |
Lisha Gajendra Marlecha v. ITD, CPC, Bengaluru |
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An individual under the new tax regime [Sec. 115BAC(1A)] whose total income is below the threshold cannot be denied the Sec. 87A rebate on Short-Term Capital Gains taxable under Sec. 111A, absent an express statutory bar. |
| Income-tax Act, 1961 |
Sec. 115BBE / 69A |
Sengodan Govindarajan v. ITO |
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The enhanced tax rate under amended Sec. 115BBE cannot be applied retrospectively to unexplained demonetization cash deposits for the assessment year in question. |
| Income-tax Act, 1961 |
Sec. 115-O / DTAA |
Siemens Ltd. v. DCIT |
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The Dividend Distribution Tax (DDT) rate paid on dividends to a foreign parent (Siemens AG, Germany) must be restricted to the beneficial tax rate specified in Article 10 of the India-Germany DTAA, subject to AO verification. |
| Income-tax Act, 1961 |
Sec. 120 / 124 |
Siemens Ltd. v. DCIT |
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If an Addl. CIT assumes jurisdiction under Sec. 120(4)(b) and the assessee fails to object within the time window prescribed by Sec. 124, the assessment order is not void ab initio. Late objections cannot invalidate completed proceedings. |
| Income-tax Act, 1961 |
Sec. 139 |
Krishnakant Kishore Palav v. ITO |
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Where an employee mistakenly included a subsequent year’s salary and TDS in the current return, procedural delays must be condoned. The matter should be remanded to the AO to check Form 26AS/12BB on merits to calculate true taxable income. |
| Income-tax Act, 1961 |
Sec. 145A |
Siemens Ltd. v. DCIT |
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If an assessee consistently uses the exclusive method (AS-2) for MODVAT/CENVAT and shows a revenue-neutral impact with zero net-profit change, the AO cannot arbitrarily add excise duty to the closing stock under Sec. 145A. |
| Income-tax Act, 1961 |
Sec. 148 |
Zaheer Syed Abbas v. UOI |
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A Sec. 148 reopening notice issued and a subsequent reassessment order passed against a company that has already been struck off and ceased to exist is illegal and void as a matter of law. |
| Income-tax Act, 1961 |
Sec. 150 / 149 |
Sonnenahalli Venkataramanappa Narayana Swamy v. ITO |
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Reopening a subsequent year’s assessment via Sec. 150(1) without a specific finding or direction from the Tribunal’s previous order is outside jurisdiction. If the standard Sec. 149 limitation has expired, the notice is void. |
| Income-tax Act, 1961 |
Sec. 271(1)(c) |
Derby Clothing (P.) Ltd. v. ITO |
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Penalty for concealment under Sec. 271(1)(c) cannot survive if the primary quantum addition that formed the very basis of the penalty has been completely deleted on appeal. |
| Income-tax Act, 1961 |
Sec. 276C / 271(1)(c) |
C.S. Projects India (P.) Ltd. v. ITO |
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If the ITAT deletes a Sec. 271(1)(c) penalty on the grounds that the assessee provided adequate evidence (implying no concealment or inaccurate particulars), the foundation for criminal prosecution under Sec. 276C vanishes, and the complaint must be quashed. |
