INCOME TAX CASE LAWS 26.10.2026
Here is the structured table containing the Relevant Act, Section, Case Law Title, Citation, and Brief Summary extracted from your text:
| Relevant Act | Section | Case Law Title | Citation | Brief Summary |
| Income-tax Act, 1961 | Section 12AB | Indian Association of Colleges of Pharmachy v. Commissioner of Income-tax (Exemptions) | Click here | Denial of Section 12AB registration on grounds of mutuality required reconsideration after verifying charitable objects, genuineness of activities, and statutory bar on asset distribution. |
| Income-tax Act, 1961 | Section 14A | Thomson Reuters International Services (P.) Ltd. v. Commissioner of Income-tax (Appeal), NFAC Delhi | Click here | Disallowance under section 14A read with Rule 8D cannot be sustained when no exempt income was earned; Explanation to section 14A added by Finance Act 2022 is not retrospective. |
| Income-tax Act, 1961 | Section 37(1) | JSW Jaigarh Port Ltd. v. Principal Commissioner of Income-tax Officer | Click here | Revisionary jurisdiction under section 263 cannot be invoked merely due to perceived inadequacy of enquiry or to take a different view on legally tenable ESOP expenditure. |
| Income-tax Act, 1961 | Section 50C | Kashmira Rajnikant Doshi v. Income-tax Officer Ward 42(1)(3) | Click Here | Upon claim that stamp duty value exceeded fair market value on tenancy right surrender, the AO must examine statutory conditions and refer the matter to the DVO under section 50C(2). |
| Income-tax Act, 1961 | Section 50C | Kashmira Rajnikant Doshi v. Income-tax Officer Ward 42(1)(3) | Click Here | Section 50C applies to the surrender of tenancy rights in immovable property as they constitute capital assets representing property rights. |
| Income-tax Act, 1961 | Section 69C | Deputy Commissioner of Income-tax v. Maharashtra Seamless Ltd. | Click here | Aggregating distinct cash payments (each below Rs. 50 lakhs) from separate orders/events to invoke extended limitation under section 149(1)(b) is impermissible; notice issued beyond 3 years was invalid. |
| Income-tax Act, 1961 | Section 72 | Kodak India (P.) Ltd. v. Deputy Commissioner of Income-tax | Click Here | The tax computation sheet must strictly align with the assessment order by granting set-off of brought forward business losses and unabsorbed depreciation. |
| Income-tax Act, 1961 | Section 80G | Indian Association of Colleges of Pharmachy v. Commissioner of Income-tax (Exemptions) | Click here | Where section 80G approval was denied solely due to rejection of section 12AB registration, restoration of 12AB registration requires fresh reconsideration for 80G approval. |
| Income-tax Act, 1961 | Section 92B | Vaibhav Global Ltd. v. Deputy Commissioner of Income-tax | Click Here | Notional interest adjustment on AE receivables cannot be made if credit terms are uniform for AEs and non-AEs, unless preferential treatment is established; missing factual verifications require factual probe. |
| Income-tax Act, 1961 | Section 92C | Vaibhav Global Ltd. v. Deputy Commissioner of Income-tax | Click Here | For a material-intensive gemstone manufacturer, Berry ratio (OP/VAE) is inappropriate; assessee’s chosen PLI-CPM or TNMM (OP/OC) should be used for ALP determination. |
| Income-tax Act, 1961 | Section 92C | Kodak India (P.) Ltd. v. Deputy Commissioner of Income-tax | Click Here | Assigning 2:1 weight to NAV and DCF values under ‘other method’ provided a balanced TP adjustment for division sale; TPO’s adjustment based solely on DCF was deleted. |
| Income-tax Act, 1961 | Section 92C | Kodak India (P.) Ltd. v. Deputy Commissioner of Income-tax | Click Here | Resale Price Method is the appropriate method for determining ALP when importing finished goods without significant value addition or processing. |
| Income-tax Act, 1961 | Section 92CE | Kodak India (P.) Ltd. v. Deputy Commissioner of Income-tax | Click Here | Secondary adjustment and additional tax under section 92CE do not apply to deemed international transactions under section 92B where the counterparty is not an AE under section 92A. |
| Income-tax Act, 1961 | Section 115JB | Vaibhav Global Ltd. v. Deputy Commissioner of Income-tax | Click Here | AO cannot add transfer pricing adjustments while computing book profit for Minimum Alternate Tax (MAT) under section 115JB. |
| Income-tax Act, 1961 | Section 148A | Purshotam Kumar Hissaria v. Assistant Commissioner of Income-tax | Click here | Reassessment order under section 148A(3) passed without granting personal hearing despite a specific request violates natural justice and is unsustainable. |
| Income-tax Act, 1961 | Section 153A | Consistent Builders (P.) Ltd. v. ACIT | Click here | Limitation under section 153A r.w.s. 153C must be computed backwards from the assessment year in which the satisfaction note is recorded; assessment for AY 2011-12 was time-barred. |
| Income-tax Act, 1961 | Section 153A | Salgaocar Mining Industries (P.) ltd. v. Deputy Commissioner of Income-tax | Click here | For a search in July 2017, the 10-year look-back period limits assessment years to 2009-10 onwards, making proceedings for AY 2008-09 invalid and without jurisdiction. |
| Income-tax Act, 1961 | Section 153C | Shikhar Kailash Infratech Ltd. v. Deputy Commissioner of Income-tax | Click Here | Recording a single consolidated satisfaction note for multiple assessment years instead of year-specific notes invalidates jurisdiction under section 153C. |
| Income-tax Act, 1961 | Section 153C | Shikhar Kailash Infratech Ltd. v. Deputy Commissioner of Income-tax | Click Here | Initiation of proceedings under section 153C where satisfaction note is recorded after 01-04-2021 is barred by section 153C(3) and void ab initio. |
| Income-tax Act, 1961 | Section 153C | Shikhar Kailash Infratech Ltd. v. Deputy Commissioner of Income-tax | Click Here | Recording a satisfaction note 17 months after completing assessment of searched person vitiates assumption of jurisdiction under section 153C. |
| Income-tax Act, 1961 | Section 270A | Alwyn Sebastian Fernades v. Income-tax Officer | Ckick Here | Penalty under section 270A deleted as bona fide explanations and genuine transactions fell under exceptions in section 270A(6)(a). |
| Income-tax Act, 1961 | Section 275 | Isha Travels and Tours (P.) Ltd v. Assistant Commissioner of Income | Click Here | Due to embargo under section 275(1)(a), AO cannot proceed with penalty proceedings during the pendency of a quantum appeal before CIT(A); proceedings must be kept in abeyance. |