INCOME TAX CASE LAWS 16.07.2026
INCOME TAX CASE LAWS 16.07.2026
Here is the structured summary of the case laws compiled into a clean, scannable table for your reference.
| Relevant Act | Section | Case Law Title | Citation | Brief Summary |
| Income-tax Act, 1961 | Section 2(14) | Superb Infotech (P.) Ltd. v. Deputy Commissioner of Income-tax |
2026
|
Profit from the sale of rural agricultural land (beyond municipal limits/not a capital asset) sold in a single transaction cannot be taxed as business income or capital gains. Subsequent non-agricultural use by the buyer is irrelevant to the seller’s tax liability. |
| Prohibition of Benami Property Transactions Act, 1988 | Section 4 | Braham Dev Sood v. Janki |
2026
|
Section 4 bars the enforcement of any right in benami property (including protection of possession) in suits filed after the Act’s enactment, regardless of when the transaction occurred (even if purchased in 1948-49). |
| Prohibition of Benami Property Transactions Act, 1988 | Section 5 | Braham Dev Sood v. Janki |
2026
|
Once a property is established as benami, neither the real purchaser nor the heirs of the original sellers can claim rights over it; the property is liable to central government acquisition without compensation. |
| Income-tax Act, 1961 | Section 14A | HDFC ERGO General Insurance Company Ltd. v. Assistant Commissioner of Income-tax |
2025
|
Section 14A read with Rule 8D is not applicable for making disallowances of expenditure incurred in relation to exempt income for assessees engaged in insurance businesses computed under Section 44. |
| Income-tax Act, 1961 | Section 14A | Poonawalla Fincorp Ltd. v. Income-tax Officer |
2026
|
No disallowance under Section 14A is warranted if no exempt income was earned during the year. The Finance Act 2022 amendment (applying disallowance even without exempt income) is prospective. |
| Income-tax Act, 1961 | Section 37(1) | HDFC ERGO General Insurance Company Ltd. v. Assistant Commissioner of Income-tax |
2025
|
Payments made by a general insurer to aggregators for motor insurance policy servicing/support are allowable business expenditures if no Insurance Act offense or IRDAI guideline violation is established. |
| Income-tax Act, 1961 | Section 45 | Tejal Kaushik Maisheri v. Assistant Commissioner of Income-tax, Central |
2026
|
An amount of ₹50 lakhs received by the assessee and spouse, intrinsically linked to land acquisition activities of a buyer group, must be taxed as part of full value of consideration in the year of sale, not under Section 69A. |
| Income-tax Act, 1961 | Section 56 | VNG Automotive (P.) Ltd. v. Assistant Commissioner of Income-tax |
2026
|
Interest earned on temporary deposits of funds earmarked for setting up a plant/machinery and adjusted against pre-operative expenses is a capital receipt (not IFOS) to be set off or capitalized under Section 35D. |
| Income-tax Act, 1961 | Section 69A | Superb Infotech (P.) Ltd. v. Deputy Commissioner of Income-tax |
2026
|
Section 153C proceedings initiated solely based on possession of partnership/dissolution deeds, without any incriminating material found during the search or link to undisclosed income, are unsustainable. |
| Income-tax Act, 1961 | Section 147 | VNG Automotive (P.) Ltd. v. Assistant Commissioner of Income-tax |
2026
|
Where an assessee adjusts interest from bank deposits against pre-operative expenses and the return was only processed under Section 143(1), assessment can be validly reopened under Section 147. |
| Income-tax Act, 1961 | Section 148 | Rudra Alloys (P.) Ltd. v. Assistant Commissioner of Income-tax |
2026
|
Notices issued under Section 148 by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC) are without jurisdiction and liable to be set aside. |
| Income-tax Act, 1961 | Section 149 | Bipinkumar Girdharlal Parekh v. Office of the Assistant Commissioner of Income-tax |
2026
|
For searches conducted prior to the Finance (No. 2) Act, 2024, if the alleged escaped income is below ₹50 lakh, the 3-year limitation under Section 149(1)(a) applies, making notices issued beyond that period invalid. |
| Income-tax Act, 1961 | Section 149 | Bhavik Bhupendra Shah v. Assistant Commissioner of Income-tax |
2026
|
A notice under Section 148 for income escaping assessment relating to AY 2015-16 issued on or after April 1, 2021, is clearly time-barred and must be set aside. |
| Income-tax Act, 1961 | Section 194A | Kavya Shaji v. Union of India |
2026
|
The TDS exemption under Section 194A(3)(ix) applies strictly to interest on the core MACT compensation award, not on the interest accumulated subsequent to depositing it in a bank fixed deposit. |
| Income-tax Act, 1961 | Section 270A | Poonawalla Fincorp Ltd. v. Income-tax Officer |
2026
|
Imposition of penalty for under-reporting is unjustified if an NBFC claimed Education Cess deduction in good faith based on then-settled law, which was subsequently disallowed via retrospective amendment. |

