INCOME TAX CASE LAWS 26.5.2026

Relevant Act	Section	Case Law Title	Citation	Brief Summary
PBPT Act, 1988	Section 2(26)	Yoosaf N A. v. Initiating Officer, (BPU)	Click Here	Unaccounted cash with an unexplained source constitutes “tangible movable property” under Sec 2(26) and qualifies as benami property when involved in a benami transaction.
PBPT Act, 1988	Section 2(9)(D)	Yoosaf N A. v. Initiating Officer, (BPU)	Click Here	Substantial cash without documentary proof of its source is rightly treated as benami property. A benami transaction requires only two parties (benamidar and beneficial owner); a three-party requirement lacks merit.
PBPT Act, 1988	Section 24	Shrenik Shah v. Initiating Officer, DCIT BPU, Ahmedabad	Click Here	Provisional attachment cannot be sustained against a property owned by an abettor unless there is a specific finding that the property itself is benami. The Act only permits attachment in the hands of a Benamidar or Beneficial Owner.
PBPT Act, 1988	Section 60	Yoosaf N A. v. Initiating Officer, (BPU)	Click Here	Offering seized cash to tax by filing an ITR does not bar PBPT Act proceedings. Declaring income without explaining its source cannot shield a person from benami confiscation proceedings.
Income-tax Act, 1961	Section 10(10AA)	Balasubramanian Venkatachalaperumal v. DCIT	Click Here	The enhanced leave encashment exemption limit of ₹25 lakh (CBDT Notification No. 31/2023) is beneficial and must be applied liberally. Full exemption of ₹19.06 lakh received on retirement was allowed.
Income-tax Act, 1961	Section 36(1)(va)	Eveready Spinning Mills (P.) Ltd. v. ACIT	Click Here	Disallowance of employees’ contribution to the Provident Fund is warranted if the remittance is made beyond the due date specified under the relevant Act.
Income-tax Act, 1961	Section 37(1)	ACIT v. APL Logistics (India) (P.) Ltd.	Click Here	Where a forex loss reversal claim was allegedly taxed twice, the matter was remanded back to the Assessing Officer for factual verification and a fresh order.
Income-tax Act, 1961	Section 68	PCIT v. Nita Rastogi	Click Here	Reassessment proceedings based solely on general information from the Investigation Wing regarding bogus LTCG, without independent material or application of mind (borrowed satisfaction), are liable to be quashed.
Income-tax Act, 1961	Section 80-IA	Eveready Spinning Mills (P.) Ltd. v. ACIT	Click Here	For captive consumption of power from an internal windmill, the market rate at which the State Electricity Board supplies power to consumers must be considered for deductions, not the procurement rate.
Income-tax Act, 1961	Section 89	Chandrashekhar Jangde v. ITO	Click Here	Substantial tax relief on salary arrears cannot be denied merely due to the belated filing of Form 10E. Time limits for such beneficial forms should be construed liberally.
Income-tax Act, 1961	Section 92C	PCIT v. Sony India (P.) Ltd.	Click Here	Transfer Pricing adjustments using the “Bright Line Test” (BLT) for AMP expenses/royalty are unsustainable as BLT is not a legally prescribed method under the Act or Rules.
Income-tax Act, 1961	Section 92C	ACIT v. APL Logistics (India) (P.) Ltd.	Click Here	In Transfer Pricing comparables for logistics/support services: exclude companies lacking segmental results or government-owned firms lacking functional similarity; include functionally similar support service providers.
Income-tax Act, 1961	Section 148	Vijender Pal Jain v. ACIT	Click Here	If a deceased assessee’s father submits to reassessment proceedings as a legal representative, he cannot later challenge the validity of the notice on the grounds that he is not a legal heir.
Income-tax Act, 1961	Section 151	Vijender Pal Jain v. ACIT	Click Here	For reopening assessments under the extended limitation period of Section 148, approval must be granted by the PCCIT; notice issued with only a PCIT approval is invalid and liable to be quashed.
Income-tax Act, 1961	Section 253	Balasubramanian Venkatachalaperumal v. DCIT	Click Here	A delay of 1165 days in filing an appeal was condoned because subsequent judicial updates and a new CBDT notification constituted a sufficient, bona fide cause for the delay.

(Note: “PBPT Act” stands for the Prohibition of Benami Property Transactions Act, 1988).