INCOME TAX CASE LAWS 20.07.2026

Here is the structured summary of the notifications and judicial precedents organized by Section, Case Title, Brief Summary, Citation, and Relevant Act.

Relevant Act	Section / Rule	Case Title / Authority	Citation / Ref. No.	Brief Summary
Income-tax Act, 2025	Sec 2(112)	CBDT Notification	Click Here	Notifies NaBFID’s 10-year Zero-Coupon Bond (issue size up to ₹20,000 crore, issued up to March 31, 2028) as an eligible zero-coupon bond.
Income-tax Act, 1961	Sec 47(viiaf)	CBDT Notification	Click Here	Grants tax-neutral status for the transfer of capital assets from NPCIL to ASHVINI under a Central Government-approved restructuring plan for FY 2025-26.
Income-tax Act, 1961	Sec 10(23FB), Sec 10(34)	Income-tax Officer v. India Infrastructure Fund	Click Here	Dividend income received by a SEBI-registered Venture Capital Fund from qualifying undertakings is exempt under Sec 10(23FB) or independently under Sec 10(34). Simultaneous claims under Sec 10(23FB), 10(34), and 10(35) are permissible.
Income-tax Act, 1961	Sec 10(35)	Income-tax Officer v. India Infrastructure Fund	Click Here	Dividend income earned by a Venture Capital Fund from deploying temporary surplus funds in liquid mutual fund units is exempt under Sec 10(35), despite enjoying benefits under Sec 10(23FB).
Income-tax Act, 1961	Sec 12A	Juba Jyoti Jubak Sangha v. CBDT	Click Here	CIT(E) improperly rejected condonation of delay for filing Form 10B audit report due to COVID-19; genuine hardship and circulars must be considered to condone delay and adjudicate exemption claims.
Income-tax Act, 1961	Sec 12AB	Tulsi Eye Hospital v. Exem Ward 2(4)	Click Here	Renewal of trust registration under Sec 12AB cannot be denied solely because FCRA renewal was rejected without independently examining the trust’s objects, activities, and nexus.
Income-tax Act, 1961	Sec 12AB	Shri Vagad Visha Oswal Murtipujak Jain Sangh v. CIT (Exemptions)	Click Here	While adjudicating a Sec 12AB renewal application, CIT(E) lacks the authority to declare prior Sec 12AA registration invalid. Natural justice also requires prior specific notice before rejecting an application for lack of a self-certified copy of an old certificate.
Income-tax Act, 1961	Sec 14A r.w. Rule 8D	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Sec 14A disallowance cannot be invoked if the assessee did not earn any exempt income during the relevant financial year.
Income-tax Act, 1961	Sec 14A r.w. Rule 8D	Paradip Port Authority v. DCIT	Click Here	Where an assessee has a large investment portfolio but earns exempt income from only specific bonds, Sec 14A disallowance must be restricted to the average value of investments that actually yielded exempt income.
ITAT Rules, 1963	Rule 24	Gudari Large Sized Multipurpose Co-operative Society Ltd. v. Pr. CCIT	Click Here	Dismissal of an appeal solely because the Authorized Representative was not in proper dress during a virtual hearing is non-sustainable; the appeal was restored to be heard on merits.
Income-tax Act, 1961	Sec 36(1)(iv)	Paradip Port Authority v. DCIT	Click Here	A one-time contribution to cover an actuarially certified deficit in an approved superannuation/pension fund is fully deductible; Rule 87 ceiling does not apply to deficit contributions.
Income-tax Act, 1961	Sec 36(1)(va), Sec 271(1)(c)	BSC C & C Joint Venture v. ACIT/DCIT	Click Here	Penalty under Sec 271(1)(c) for delayed deposit of employees’ PF contribution is invalid if the AO failed to record proper satisfaction prior to initiating penalty proceedings.
Income-tax Act, 1961	Sec 37(1)	Paradip Port Authority v. DCIT	Click Here	Disallowance of software expenses cannot be sustained merely because the payee failed to respond to Sec 133(6) or was struck off, provided genuine transactions/invoices/TDS exist. Also holds that CSR expenses incurred by non-corporate statutory bodies and audited recurring provisions for accrued liabilities are allowable.
Income-tax Act, 1961	Sec 37(1)	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Interest paid under Sec 7Q of the EPF Act for delayed remittance is compensatory and deductible under Sec 37(1), whereas damages under Sec 14B are penal and non-deductible.
Income-tax Act, 1961	Sec 43B	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Where a provision for sick leave previously disallowed under Sec 43B is written back into income, AO must verify past disallowance and grant corresponding relief.
Income-tax Act, 1961	Sec 56, Rule 11UA	Geomysore Services (India) (P.) Ltd. v. ITO	Click Here	If a DCF valuation report for share premium has defects, the AO cannot forcibly replace it with the NAV method; the AO must obtain a fresh valuation report from an approved valuer using the DCF method.
Income-tax Act, 1961	Sec 68	DCIT v. Pinkiben Riddheshkumar Bhandari	Click Here	Additions for LTCG on share sales as accommodation entries cannot be sustained under Sec 68 when bank statements, broker notes, and valid sales prove genuine transactions with no price-rigging evidence.
Income-tax Act, 1961	Sec 80-IA, Sec 80A(2)	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Sec 80-IA deduction is allowable up to the Gross Total Income (subject to Sec 80A(2)) and is not restricted merely to the heads of business income.
Income-tax Act, 1961	Sec 89	Ram Dattatray Kaldate v. ITO	Click Here	Settlement amounts received by an ex-employee under a voluntary retirement scheme after plant closure constitute a non-taxable capital receipt since there was no forced termination of employment.
Income-tax Act, 1961	Sec 115BAC	Balshiram Dattatray Thorat v. ITO	Click Here	A minor clerical error in mentioning the first opted year in the return does not invalidate eligibility under the new tax regime (Sec 115BAC) if Form 10-IE was validly submitted earlier and never withdrawn.
Income-tax Act, 1961	Sec 115JB	Pushkar Chemical and Fertilisers Ltd. v. DCIT	Click Here	A capital subsidy (Nutrient Based Subsidy) exempt under normal provisions must be excluded from book profits for MAT computation under Sec 115JB.
Income-tax Act, 1961	Sec 127	MS Agarwal Foundries (P.) Ltd. v. DCIT	Click Here	Prior notice or hearing is not mandatory for intra-city transfer of cases between Assessing Officers under Sec 127.
Income-tax Act, 1961	Sec 151, Sec 148	India Land Ventures Ltd. v. DCIT (Int’l Tax)	Click Here	Sanction for issuing a Sec 148 notice after three years granted by a Principal Commissioner instead of the Chief Commissioner renders the reassessment proceedings void for lack of jurisdiction.
Income-tax Act, 1961	Sec 153C	Pankajkumar Kanaiyalal Soni v. ITO	Click Here	Reassessment under Sec 153C based on seized digital material is barred by limitation if the assessment year falls beyond the permissible 10-year limit from the date the material is received by the jurisdictional AO.
Income-tax Act, 1961	Sec 154	Pushkar Chemical and Fertilisers Ltd. v. DCIT	Click Here	Settlement under DTVSV does not erase original orders; hence, the limitation period under Sec 154(7) for rectification must be calculated from the original reassessment order date.
Income-tax Act, 1961	Sec 199, Sec 194Q	Bhandari Bros v. ITO	Click Here	A commission agent (Kaccha Arahtia) is entitled to TDS credit reflected under his PAN, even if deducted erroneously by purchasers, as long as the tax has been deposited in the Government Treasury.