| Income-tax Act, 1961 |
Section 2 |
Kutchi Jain Foundation v. Commissioner of Income Tax (E) |
Providing interest-free loans to needy individuals under a structured scheme for basic residential housing constitutes “relief of poor” and does not become a commercial activity merely because it is repayable or structured. |
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| Income-tax Act, 1961 |
Section 10(10B) |
Gudla Rao v. ITO |
Ex-gratia compensation received by BSNL employees under VRS-2019 is eligible for exemption under Section 10(10B), subject to verifying conditions such as qualifying as a workman. |
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| Income-tax Act, 1961 |
Section 11 |
Ranganathan Rajeswari Charitable Trust v. ACIT (Exemption) |
Exemption under Sections 11 and 12 cannot be denied for AY 2020-21 when the rejection of transitional Form 10A did not revoke original Section 12AA registration. |
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| Income-tax Act, 1961 |
Section 12A |
Vardhman Sadhumargi Sthanakvasi Jain Shravak Sangh v. Commissioner of Income-tax (Exemption) |
Rejection of Section 12A registration cannot stand solely on the ground that some objects are restricted to a specific community without proving specific application of income/expenditure benefiting only that community. |
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| Income-tax Act, 1961 |
Section 12AB |
Vardhman Sadhumargi Sthanakvasi Jain Shravak Sangh v. Commissioner of Income-tax (Exemption) |
A proposed resolution to amend trust objects, not approved or registered under the relevant Public Trust Act, does not replace the existing registered trust deed. |
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| Income-tax Act, 1961 |
Section 12AB |
Vardhman Sadhumargi Sthanakvasi Jain Shravak Sangh v. Commissioner of Income-tax (Exemption) |
Rejection of Section 12A registration without independently examining the genuineness of activities or actual income application cannot be sustained. |
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| Income-tax Act, 1961 |
Section 14A |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Rule 8D disallowance cannot be applied to all investments when sufficient own funds exist, and post-2022 amendment does not apply retrospectively to concerned years. |
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| Income-tax Act, 1961 |
Section 14A |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Notional disallowance computed under Section 14A/Rule 8D cannot be added to book profit under Section 115JB without identifying specific debited expenditure. |
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| Income-tax Act, 1961 |
Section 14A |
Deputy Commissioner of Income-tax v. EYGBS (India) (P.) Ltd. |
Ad hoc disallowance of 5% of dividend income under Section 14A is deleted where Tribunal previously confirmed its deletion in the assessee’s own case. |
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| Income-tax Act, 1961 |
Section 32 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Depreciation on opening WDV of trademark rights is allowable from the date of ownership acquisition rather than the expiration date of earlier licensee rights. |
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| Income-tax Act, 1961 |
Section 32 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Disallowance of building block depreciation made solely on findings of an earlier year requires recomputation based on the finalized WDV of that earlier year. |
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| Income-tax Act, 1961 |
Section 35 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Under the pre-01.07.2016 regime, non-furnishing of Form 3CL/DSIR quantification does not restrict weighted R&D deduction if actual eligible expenditure is verified. |
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| Income-tax Act, 1961 |
Section 35 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Weighted deduction under Section 35(2AB) cannot be denied for want of Forms 3CK/3CM/3CL when 100% deduction is accepted and DSIR facility recognition exists. |
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| Income-tax Act, 1961 |
Section 36 |
Jeetmal Choraria v. ACIT, Central |
Disallowance of bad debts/expenses based on seized server entries cannot be sustained when additions from the same server entries were previously deleted. |
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| Income-tax Act, 1961 |
Section 36(1)(iii) |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Proportionate interest disallowance on capital advances is unsustainable where capitalized borrowing costs are identified and sufficient interest-free funds are available. |
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| Income-tax Act, 1961 |
Section 37 |
Deputy Commissioner of Income-tax v. EYGBS (India) (P.) Ltd. |
Mark-to-market foreign exchange loss arising from year-end restatement of foreign currency items is deductible as business expenditure under Section 37(1). |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Prior-period expenses claimed for the first time in the current year cannot be disallowed simply because the invoice pertains to the preceding year. |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Electricity expenses for premises used for business cannot be disallowed as personal merely because the utility bill classifies the premises as residential. |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Disallowance of genuine office expenses based merely on differences between billing addresses and GST-declared addresses is unjustified. |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Expenditure on repairs, maintenance, and allied works on leased premises is allowable as routine revenue expenditure. |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Annual SAP licence fees and customization charges for existing software are revenue expenditures and fully allowable. |
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| Income-tax Act, 1961 |
Section 37(1) |
Jeetmal Choraria v. ACIT, Central |
Apportionment of software support expenditure spanning multiple financial years is consistent with matching principles; disallowance for future periods is valid. |
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| Income-tax Act, 1961 |
Section 37(1) |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Professional fees paid to obtain an NOC for improved access to a factory without acquiring land ownership are allowable revenue expenditure. |
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| Income-tax Act, 1961 |
Section 40 |
Jeetmal Choraria v. ACIT, Central |
Disallowance for non-deduction of TDS applies to maintenance charges without explanation, but not to lease line charges as per judicial precedent. |
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| Income-tax Act, 1961 |
Section 40 |
Jeetmal Choraria v. ACIT, Central |
Deduction of tax at a lower rate does not trigger Section 40(a)(ia) disallowance on that amount, though disallowance stands for un-deducted balance amounts. |
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| Income-tax Act, 1961 |
Section 40A |
Jeetmal Choraria v. ACIT, Central |
Section 40A(3) cash payment disallowances are restricted strictly to individual payments exceeding ₹10,000 to a single payee on a single day. |
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| Income-tax Act, 1961 |
Section 43A |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Factual verification and reconciliation of forex fluctuation entries are required to correctly quantify adjustments under Section 43A. |
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| Income-tax Act, 1961 |
Section 43CA |
Tatia Developers (P) Ltd. v. Income-tax Officer |
Rearranging land ownership via reciprocal registered conveyance deeds without monetary consideration does not justify invoking stamp duty valuation under Section 43CA. |
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| Income-tax Act, 1961 |
Section 56 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Interest income offered to tax in a preceding year cannot be added again in a subsequent year, as it amounts to duplicate addition. |
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| Income-tax Act, 1961 |
Section 56 |
PH4 Food and Beverages (P.) Ltd. v. DCIT |
Consideration received against Fully Compulsorily Convertible Debentures (FCCDs) cannot be taxed under Section 56(2)(viib) prior to their conversion into equity shares. |
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| Income-tax Act, 1961 |
Section 68 |
Jeetmal Choraria v. ACIT, Central |
Opening journal entry balances brought forward from past years without fresh cash receipts in the current year cannot be added as unexplained cash credits. |
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| Income-tax Act, 1961 |
Section 68 |
Jeetmal Choraria v. ACIT, Central |
Brought-forward opening entries in ledger accounts without evidence of current-year receipts or identified creditors are not taxable under Section 68. |
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| Income-tax Act, 1961 |
Section 68 |
Jeetmal Choraria v. ACIT, Central |
Credit entries in dummy or adjustment ledger accounts that act as contra entries without actual receipt of money cannot be isolated and added under Section 68. |
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| Income-tax Act, 1961 |
Section 69A |
Jeetmal Choraria v. ACIT, Central |
Additions for undisclosed commission/interest based selectively on credit entries while ignoring debit and contra entries from trial balances are unsustainable. |
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| Income-tax Act, 1961 |
Section 69A |
Jeetmal Choraria v. ACIT, Central |
Uncorroborated WhatsApp chats lacking a Section 65B certificate or evidence of actual cash receipt cannot form the basis for Section 69A additions. |
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| Income-tax Act, 1961 |
Section 80G |
Kutchi Jain Foundation v. Commissioner of Income Tax (E) |
Rejection of Section 80G approval tied to Section 12AB registration must be restored for fresh adjudication when the Section 12AB issue is remanded. |
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| Income-tax Act, 1961 |
Section 80JJAA |
Jeetmal Choraria v. ACIT, Central |
Deduction quantified by the AO under Section 80JJAA is sustained where the assessee fails to present new arguments against the reduced amount before the Tribunal. |
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| Income-tax Act, 1961 |
Section 92C |
Deputy Commissioner of Income-tax v. EYGBS (India) (P.) Ltd. |
Exclusion of comparables lacking segmental data, failing employee cost filters, or operating in dissimilar domains is justified for benchmarking ITeS providers. |
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| Income-tax Act, 1961 |
Section 92C |
Loma Co-Developers 1 (P.) Ltd. v. Dy. CIT |
Introduction of an ad hoc tenure filter by the TPO to reject external CUP benchmarks without economic rationale is unsustainable. |
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| Income-tax Act, 1961 |
Section 94B |
Loma Co-Developers 1 (P.) Ltd. v. Dy. CIT |
Additional disallowance under Section 94B must consider only AE interest under Section 94B(1) to prevent double disallowance with transfer pricing adjustments. |
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| Income-tax Act, 1961 |
Section 143 |
Ceat Ltd. v. Deputy Commissioner of Income-tax |
Assessment completed on revised returns without issuing a mandatory Section 143(2) notice is without jurisdiction, and Section 292BB cannot cure this defect. |
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| Income-tax Act, 1961 |
Section 143 |
Jeetmal Choraria v. ACIT, Central |
Post-April 2021 search assessments under Section 143(3) completed without initiating proceedings under Sections 147/148/148B suffer from jurisdictional defects. |
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| Income-tax Act, 1961 |
Section 148 |
Tirath Ram Surinder Paul v. Income-tax Officer |
Reassessment notices issued under Section 148 for AY 2015-16 after statutory deadlines are invalid and quashed based on Supreme Court precedents. |
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| Income-tax Act, 1961 |
Section 149 |
Appnell Holdings Ltd. v. Deputy Commissioner of Income-tax, International Taxation |
Reassessment for AY 2015-16 initiated under the old regime where Section 148A(d) orders were passed after 01.04.2021 is time-barred. |
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| Income-tax Act, 1961 |
Section 270A |
ACIT v. New India Assurance Co. Ltd. |
Penalty under Section 270A for misreporting cannot stand if the order fails to specify circumstances under Section 270A(9) and computes penalty at 50% instead of 200%. |
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| Income-tax Act, 1961 |
Section 270A |
ACIT v. New India Assurance Co. Ltd. |
Penalty under Section 270A cannot be sustained on additions that have been restored to lower authorities for fresh verification and lack finality. |
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| Income-tax Act, 1961 |
Section 270A |
ACIT v. New India Assurance Co. Ltd. |
Penalty for under-reporting is not applicable where a bona fide error occurred regarding acquisition dates, provided full disclosures were made. |
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| Income-tax Act, 1961 |
Section 270A |
ACIT v. New India Assurance Co. Ltd. |
Section 270A penalty does not survive on underlying additions that are subsequently deleted in quantum proceedings by the Tribunal. |
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| Income-tax Act, 1961 |
Section 292C |
Jeetmal Choraria v. ACIT, Central |
Presumption under Section 292C is inapplicable to digital data (pen-drives) where recovery is questionable, 65B certificates are missing, and independent corroboration is absent. |
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