INCOME TAX CASE LAWS 20.08.2026
| Section | Case Law Title | Brief Summary | Citation | Relevant Act |
|---|---|---|---|---|
| Section 4 | Mumbai Port Authority v. ACIT (Exemption) | Addition of capitalised interest (50% per loan agreement) was not sustainable since the assessee already accounted for the full interest income in its books under the mercantile system. | Click Here | Income-tax Act, 1961 |
| Section 5 | Mumbai Port Authority v. ACIT (Exemption) | Infrastructural installations such as docks, sea walls, piers, wharves, railways, and rolling stock of a port are to be treated as plant and machinery eligible for higher depreciation, not as buildings. | Click Here | Income-tax Act, 1961 |
| Section 32 | Mumbai Port Authority v. ACIT (Exemption) | Where demolition proceeds were not reduced from the block of assets in the current year but claimed to be reduced in the subsequent year, verification was directed to prevent double adjustment. | Click Here | Income-tax Act, 1961 |
| Section 32 | Mumbai Port Authority v. ACIT (Exemption) | Unrecovered billed estate rentals subject to ongoing litigation/disputes cannot be added as accrued income; only real income actually realized is taxable. | Click Here | Income-tax Act, 1961 |
| Section 36(1)(iii) | Arvind Kumar Singhavi v. Income-tax Officer | Disallowance of interest paid at 15% on unsecured loans by benchmarking against a notional 12% rate was deleted; borrowing terms are the assessee’s prerogative and 15% was reasonable. | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Arvind Kumar Singhavi v. Income-tax Officer | Disallowance of expenses corresponding to additions to building and furniture reflected as business assets in the balance sheet was unjustified and deleted. | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Disallowance of salary paid to expatriate employees made in disregard of binding DRP directions following identical facts in earlier years was unsustainable. | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Mumbai Port Authority v. ACIT (Exemption) | Donations and contributions connected to labour welfare, employee relations, and industry bodies have a direct nexus with business operations and are deductible under Section 37(1). | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Mumbai Port Authority v. ACIT (Exemption) | CSR contributions made under mandatory government guidelines prior to the insertion of Explanation 2 to Section 37(1) are allowable as business expenditure. | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Mumbai Port Authority v. ACIT (Exemption) | Payment made to SBI towards an employee Leave Encashment Scheme with actual fund outflow and liability assumption by the insurer is an allowable business expense, not hit by Section 43B(f). | Click Here | Income-tax Act, 1961 |
| Section 37(1) | Principal Commissioner of Income-tax v. LTI Mindtree Ltd. | SLP dismissed; provision for discount discharged fully in the subsequent assessment year is an allowable business expenditure and raises no substantial question of law. | Click Here | Income-tax Act, 1961 |
| Section 40(a)(ia) | Mumbai Port Authority v. ACIT (Exemption) | Where underlying demand orders under Sections 201(1) and 201(1A) for non-deduction of TDS did not survive, consequential disallowance under Section 40(a)(ia) could not be sustained. | Click Here | Income-tax Act, 1961 |
| Section 68 | Mahendra Gumanmalji Lodha v. Assistant Commissioner of Income-tax Circle 5(2)(1) | Reopening under Section 148 without fresh tangible material to re-examine bank entries already scrutinized under Section 143(3) constitutes an impermissible change of opinion. | Click Here | Income-tax Act, 1961 |
| Section 68 | Ganesh Prasad Khetan v. Principal Commissioner of Income-tax | Revision order under Section 263 set aside where Pr. CIT failed to conduct independent inquiries or record categorical findings showing how the assessment order was erroneous and prejudicial. | Click Here | Income-tax Act, 1961 |
| Section 68 | ACIT v. Maheshwari Coal Benefication and Infrastructure (P.) Ltd. | Cash credit additions and consequential interest disallowance were deleted where unsecured loans from corporate entities were fully repaid prior to completion of the assessment. | Click Here | Income-tax Act, 1961 |
| Section 69A | Pawan Onkardas Chandak v. ACIT | Unexplained cash additions for mother and children were deleted by applying the doctrine of telescoping, recognizing past judicial findings, customary savings, gifts, and pin money. | Click Here | Income-tax Act, 1961 |
| Section 69C | Chandra Mohan v. Office of the ACIT | Additions made on the basis of third-party statements and seized documents without granting cross-examination violate principles of natural justice and cannot be sustained. | Click Here | Income-tax Act, 1961 |
| Section 80G | Shri Sanatan Dharm Venkuth Dhamsewa Samiti v. Commissioner of Income-tax (Exemptions) | Rejection of Section 80G approval purely due to incidental religious activities without evaluating dominant objects or the 5% statutory spending threshold was remanded for de novo adjudication. | Click Here | Income-tax Act, 1961 |
| Section 80-IA | N. R. Agarwal Industries Ltd. v. NFAC, Delhi | Allocation of common costs between electricity and measurable low-pressure steam based on meters and logbooks was upheld; entire costs cannot be loaded onto electricity to deny Section 80-IA deduction. | Click Here | Income-tax Act, 1961 |
| Section 92B | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | AMP expenditure incurred independently for the taxpayer’s own domestic business without an arrangement/obligation for foreign AE brand building is not an international transaction. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Foreign exchange gains arising out of normal business operations must be treated as operating in nature for computing operating margins of both the assessee and comparables. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Transfer pricing adjustments must be restricted proportionately only to transactions with Associated Enterprises (AEs) and cannot be applied to transactions with unrelated third parties. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | An entity owning intangibles, running internal R&D, and manufacturing mobile network repeaters is functionally dissimilar to a licensed manufacturer of consumer electronics/home appliances. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | A company manufacturing washing machines, microwaves, and ACs that satisfies the 75% manufacturing filter is functionally comparable to the assessee’s licensed manufacturing segment. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Under the rule of consistency, a company with an unchanged functional profile accepted as a comparable in the immediately preceding year must be retained in the final set. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Service provider entities cannot be selected as comparables against an assessee deriving revenue predominantly from the trading of telecommunication equipment. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | A low-risk high-sea trader with flash title correctly excludes COGS and uses Berry Ratio under ‘Other Method’; segregated benchmarking cannot be forcibly bundled under TNMM. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | CUP method cannot be applied to benchmark consumer electronics technical royalties using unrelated third-party licensing agreements from the agricultural sector. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | A company whose revenue is substantially driven by air-conditioners is functionally dissimilar to an assessee operating a diversified white-goods manufacturing business. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Operating margins must be recomputed by including all operational items having a direct business nexus and excluding non-operational/financing items. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Working capital adjustments directed by the DRP and consistently allowed in preceding years must be granted under the principle of consistency. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Exclusion on the ground of different FY-end was remanded for factual verification where the comparable had altered its year-end from December to March to align with the assessment year. | Click Here | Income-tax Act, 1961 |
| Section 92C | Samsung India Electronics (P.) Ltd. v. Addl. Commissioner of Income-tax, National E-Assessment Centre, New Delhi | Comparables manufacturing similar consumer electronic goods cannot be rejected solely due to different accounting year-ends if they meet all quantitative filters. | Click Here | Income-tax Act, 1961 |
| Section 145 | Arvind Kumar Singhavi v. Income-tax Officer | Rejection of books and ad-hoc estimation of GP at 15% is unjustified when the declared GP of 12.62% falls within the AO’s acknowledged industry range and no specific defects exist. | Click Here | Income-tax Act, 1961 |
| Section 148 | Mrunal Santramdas Varma v. Assistant Commissioner of Income-tax | Reassessment notice based on third-party broker loose papers lacking direct reference or a live nexus to the assessee’s transaction is invalid and liable to be quashed. | Click Here | Income-tax Act, 1961 |
| Section 148 | Chandra Mohan v. Office of the ACIT | Assumption of jurisdiction under Section 148 is valid where search of a third party reveals digital data indicating unrecorded transactions, following AO’s satisfaction and PCIT approval. | Click Here | Income-tax Act, 1961 |
| Section 148 | Chandra Mohan v. Office of the ACIT | Returns filed belatedly without extension in response to a Section 148 notice fall under the 3rd proviso to Section 148; issuance of notice under Section 143(2) is not mandatory before reassessment. | Click Here | Income-tax Act, 1961 |
| Section 149 | Chandra Mohan v. Office of the ACIT | For the extended limitation period under Section 149(1)(b), only the embedded profit element of alleged bogus purchases constitutes escaped income, not the gross purchase value. | Click Here | Income-tax Act, 1961 |
| Section 149 | Chandra Mohan v. Office of the ACIT | For a non-searched person, the limitation block period runs from the date of handover/action initiation, not the original search date; assessments beyond 6 years are time-barred. | Click Here | Income-tax Act, 1961 |
| Section 149 | Chandra Mohan v. Office of the ACIT | Digital data seized from a third party cannot be treated as the assessee’s own books of account to invoke extended limitation under Section 149(1)(b)(iii). | Click Here | Income-tax Act, 1961 |
| Section 151 | Assistant Commissioner of Income-tax v. Chetan Gopaldas Cholera | SLP dismissed; for reassessments falling within the four-year window under relaxation provisions, sanction of the JCIT under Section 151(2) is mandatory; approval by PCIT renders notice invalid. | Click Here | Income-tax Act, 1961 |
| Section 151 | Income-tax Officer v. Satkar Caterers (P.) Ltd. | Reassessment notice quashed where approval was obtained from PCIT instead of the competent authority (JCIT) under Section 151(2) read with TOLA, 2020. | Click Here | Income-tax Act, 1961 |
| Section 201 | State Bank of India v. Deputy Commissioner of Income-tax, TDS | Assessee cannot be treated in default under Section 201(1) or charged interest under Section 201(1A) for non-deduction of TDS on foreign LTC while operating under interim High Court stay orders. | Click Here | Income-tax Act, 1961 |
| Section 201 | State Bank of India v. Income-tax Officer, TDS | Non-deduction of TDS on LTC/LFC involving foreign travel under the protection of binding High Court interim directions does not attract default status or interest under Sections 201(1)/201(1A). | Click Here | Income-tax Act, 1961 |
| Section 276C | Dinar Tarcar Resources (India) (P.) Ltd. v. Income-tax Department | Inability to pay tax due to business closure does not constitute wilful tax evasion under Section 276C(2) where payments were made in parts and fully cleared with interest. | Click Here | Income-tax Act, 1961 |
| Section 276CC | Surinder Sabhlok v. Deputy Commissioner of Income-tax | SLP granted against HC order holding that filing a belated return under Section 139(4) does not absolve the assessee from prosecution for failure to file within the due date under Section 139(1). | Click Here | Income-tax Act, 1961 |
| Section 276CC | Surinder Sabhlok v. Deputy Commissioner of Income-tax | SLP granted against HC order holding that wilfulness and the effect of search proceedings are questions of fact to be decided during trial and cannot be adjudicated in writ jurisdiction. | Click Here | Income-tax Act, 1961 |
| Section 276CC | Surinder Sabhlok v. Deputy Commissioner of Income-tax | SLP granted against HC order holding that completion of assessment is not a mandatory prerequisite for launching prosecution under Section 276CC. | Click Here | Income-tax Act, 1961 |
| Section 276CC | Surinder Sabhlok v. Deputy Commissioner of Income-tax | SLP granted against HC order holding that the statutory presumption under Section 278E places the burden on the accused to disprove mens rea, which cannot be decided summarily. | Click Here | Income-tax Act, 1961 |