INCOME TAX CASE LAWS 24.06.2026

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Income Tax Act, 1961	Sec 2(14)	Chakravati Chiman v. Income-tax Officer	$2026$ Click Here	Where Sub-Registrar documents and the sale deed confirmed the rural agricultural nature of land, and no contrary evidence was presented, the addition of LTCG was deleted.
Income Tax Act, 1961	Sec 10(23EA)	Deputy Commissioner of Income-tax v. National Stock Exchange Investor Protection Fund Trust	$2026$ Click Here	Denial of exemption under Sec 10(23EA) during Sec 143(1) processing without prior intimation is procedurally invalid. Further, denying it by invoking Sec 11(7) is a debatable issue outside the scope of Sec 143(1) adjustments.
Income Tax Act, 1961	Sec 11	Mahaveer Pratishthan v. Commissioner of Exemption, Pune	$2026$ Click Here	Once the delay in filing the main return is condoned, refusing to condone the delay in filing Form 10 (caused by a CA’s lapse) is unsustainable if the audit report was filed on time.
Income Tax Act, 1961	Sec 12A	Shri 1008 Digambar Jain Atishay Kshetra Papoura Ji v. Income Tax Officer-Exemption	$2026$ Click Here	The benefit of the proviso to Sec 12A(2) operates retrospectively during the pendency of an assessment for an earlier year if Sec 12AA registration is obtained during such pendency.
Income Tax Act, 1961	Sec 14A	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Disallowance under Sec 14A read with Rule 8D must strictly be restricted/capped at the actual amount of exempt dividend income earned during the year.
Income Tax Act, 1961	Sec 14A	T.V. Today Network Ltd. v. ACIT	$2026$ Click Here	No disallowance under Sec 14A read with Rule 8D is warranted if the investments made did not yield any exempt income during the relevant financial year.
Income Tax Act, 1961	Sec 32	T.V. Today Network Ltd. v. ACIT	$2026$ Click Here	Workforce acquired from a holding company via a slump sale and capitalized as an intangible asset qualifies as “business or commercial rights of similar nature” and is eligible for depreciation.
Income Tax Act, 1961	Sec 36(1)(vii)	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Where advisory/merchant banking income was recognized in an earlier year, writing off the outstanding receivable as bad debts in the books satisfies Sec 36(1)(vii) read with Sec 36(2).
Income Tax Act, 1961	Sec 37(1)	T.V. Today Network Ltd. v. ACIT	$2026$ Click Here	Interest paid to the Ministry for a delayed FM radio station migration fee under Phase-III is compensatory in nature and allowable as a revenue expenditure.
Income Tax Act, 1961	Sec 40(a)(ia)	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	No disallowance is attracted for tea/coffee payments below the TDS threshold, or for employee reimbursements where the privity of contract exists only between the employee and the third-party vendor.
Income Tax Act, 1961	Sec 56	Shreyas Naynesh Modi v. Income-tax Officer	$2026$ Click Here	If a stamp duty valuation is disputed and referred to the DVO, the safe harbour tolerance margin under Sec 56(2)(x) must be applied to the FMV determined by the DVO.
Income Tax Act, 1961	Sec 68	AKR Poly Industries v. Income-tax Officer	$2026$ Click Here	Unexplained sundry creditors with no established source or identity are correctly assessed as deemed income under Sec 68 as “Income from Other Sources,” not business income.
Income Tax Act, 1961	Sec 68	Shri 1008 Digambar Jain Atishay Kshetra Papoura Ji v. Income Tax Officer-Exemption	$2026$ Click Here	Cash donations deposited during demonetization properly recorded in audited books and offered to tax cannot be added under Sec 68 where trust objectives/books are not doubted.
Income Tax Act, 1961	Sec 68	Deputy Commissioner of Income-tax v. Vedanta Resources (P.) Ltd.	$2026$ Click Here	Deletion of Sec 68 addition is justified when complete transaction trails of unlisted equity sales (purchaser details, banking channels, Sec 11UA valuation, bills) are furnished.
Income Tax Act, 1961	Sec 68	Baleshwar Sharma v. Deputy Commissioner of Income-tax, Central	$2026$ Click Here	An assessment based solely on loose slips seized from a third party without offering a proper opportunity to cross-examine violates natural justice and requires fresh adjudication.
Income Tax Act, 1961	Sec 69B	Chakravati Chiman v. Income-tax Officer	$2026$ Click Here	No addition under Sec 69B or application of Sec 115BBE is justified for ancestral agricultural land where records establish its hereditary nature and zero purchase cost.
Income Tax Act, 1961	Sec 69C	Diach Chemicals and Pigments (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Additions based on sheer estimations and surmises under Sec 69C are unsustainable when purchases are fully backed by audited books, third-party confirmations, and documentation.
Income Tax Act, 1961	Sec 69C	Nilgiri Dairy Farm (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	A simple ad-hoc or estimated disallowance of recorded business expenditures cannot be classified as “unexplained expenditure” under Sec 69C to invoke Sec 115BBE.
Income Tax Act, 1961	Sec 80G	Gram Bartori Vikas Shikshan Samiti v. Commissioner of Income-tax (Exemption)	$2026$ Click Here	Rejecting a final Sec 80G approval in Form 10AB solely on the grounds of delay without examining the charitable objects or genuineness of the trust is unsustainable.
Income Tax Act, 1961	Sec 80G	T.V. Today Network Ltd. v. ACIT	$2026$ Click Here	A corporate taxpayer can claim a Sec 80G deduction for CSR expenditures paid to an approved entity (e.g., Care Today Fund), as there is no specific statutory bar against it.
Income Tax Act, 1961	Sec 80-IA	AKR Poly Industries v. Income-tax Officer	$2026$ Click Here	Unexplained sundry creditors added as income under Sec 68 cannot be treated as operational business income for computing deductions under Sec 80-IA or 80-IB.
Income Tax Act, 1961	Sec 80P	Panchagangavali Souharda Credit Co-operative Ltd. v. Income-tax Officer	$2026$ Click Here	Admitting nominal members past the 15% state law limit does not warrant a blanket denial of Sec 80P; the disallowance must be restricted strictly to income from the excess members.
Income Tax Act, 1961	Sec 80P	Panchagangavali Souharda Credit Co-operative Ltd. v. Income-tax Officer	$2026$ Click Here	If a hybrid accounting method leads to an addition (disallowing interest payable provisions), a Sec 80P deduction is allowable on the enhanced profit since it stems from member activities.
Income Tax Act, 1961	Sec 115BBE	Nilgiri Dairy Farm (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Rectification under Sec 154 cannot be used to apply Sec 115BBE rates after immunity under Sec 270AA was granted, as it fundamentally alters tax consequences beyond the scope of Sec 154.
Income Tax Act, 1961	Sec 115BBE	Shri 1008 Digambar Jain Atishay Kshetra Papoura Ji v. Income Tax Officer-Exemption	$2026$ Click Here	Where the income pertains to the regular activities of the relevant year, the revenue cannot arbitrarily charge tax at the special rate under Sec 115BBE instead of normal rates.
Income Tax Act, 1961	Sec 127	Xavient Information Systems (I.) (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	An assessment order completed by an AO in New Delhi is completely without jurisdiction if no formal transfer order under Sec 127 was issued from the Mumbai AO.
Income Tax Act, 1961	Sec 144C	Marvell India (P.) Ltd. v. DCIT Circle 4(1)(1)	$2026$ Click Here	Issuing two separate draft assessment orders (one for TP and one for corporate tax) is invalid. Sec 144C mandates a single, consolidated draft assessment order.
Income Tax Act, 1961	Sec 156	Drake & Scull Water & Energy India (P.) Ltd. v. National Faceless Assessment Centre	$2026$ Click Here	Income tax demands not included in an NCLT-approved CIRP resolution plan stand extinguished under the clean slate principle, and past recoveries must be refunded with interest.
Income Tax Act, 1961	Sec 194C	ICICI Securities Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	In the absence of a written or oral catering contract, the mere supply of tea/coffee cannot be presumed as a contract service to attract TDS obligations under Sec 194C.