INCOME TAX CASE LAWS 27.08.2026

Section	Case Law Title	Brief Summary	Citation	Relevant Act
Section 4	Biodiversity Conservation Society of Telangana (BIOSOT) v. Union of India	Where BIOSOT, a statutory society discharging sovereign functions under Article 48A, functioned as an instrumentality of the State, its receipts were immune from income tax under Article 289(1), making bank attachment notices under section 226(3) unsustainable in law.	Click Here	Income-tax Act, 1961
Section 10(5)	Subba Rayudu Kalikiri v. Income-tax Officer	Matter remanded to verify air tickets and boarding passes produced before the Tribunal to establish the LTA claim, as these were not filed before the AO.	Click Here	Income-tax Act, 1961
Section 10(10AA)	Karthikeyan v. Income-tax Officer	Non-government retirees are entitled to the enhanced leave encashment exemption limit (raised from ₹3 lakh to ₹25 lakh) to align with government employees.	Click Here	Income-tax Act, 1961
Section 10A	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	Telecom and foreign exchange expenses not billed to or recovered from customers cannot be reduced from export turnover while computing section 10A deduction.	Click Here	Income-tax Act, 1961
Section 12AB	ST. Josephs High School v. CIT (Exemption)	Application for renewal of registration under section 12AB cannot be summarily rejected for lack of a formal trust deed if alternate registration documents (e.g., Charity Commissioner records) are provided per Rule 17A.	Click Here	Income-tax Act, 1961
Section 14A	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	Rule 8D disallowance made without objective satisfaction was remanded; only investments yielding exempt income are to be considered, verifying if own funds were utilized.	Click Here	Income-tax Act, 1961
Section 32	Procter & Gamble Home Products (P.) Ltd. v. Additional Commissioner of Income-tax	Depreciation on moulds and dies used for packing final products during the year is allowable as the “put to use” condition stands satisfied.	Click Here	Income-tax Act, 1961
Section 37(1)	Procter & Gamble Home Products (P.) Ltd. v. Additional Commissioner of Income-tax	Ad hoc disallowance of trade incentive and brand promotion expenses was deleted, following the Tribunal’s precedent on identical facts for a subsequent year.	Click Here	Income-tax Act, 1961
Section 37(1)	Subba Rayudu Kalikiri v. Income-tax Officer	Claim for reimbursement of official food and conveyance expenses remanded for reconsideration and verification of supporting evidence.	Click Here	Income-tax Act, 1961
Section 37(1)	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	Deduction claim for Education Cess as business expenditure stands rightly rejected in view of the retrospective amendment introduced by the Finance Act, 2022.	Click Here	Income-tax Act, 1961
Section 40	IBS Software (P.) Ltd. v. Union of India	Reassessment notice under section 148A is valid if it conveys the relevant details of information, as the law does not require mandatory disclosure of the information source.	Click Here	Income-tax Act, 1961
Section 48	Ameeta Jagdish Thackersey v. Income-tax Officer	Due to divergent Tribunal views on deducting Portfolio Management Services (PMS) fees, the view favorable to the assessee was adopted, allowing PMS fees as a deduction in computing capital gains.	Click Here	Income-tax Act, 1961
Section 56	Procter & Gamble Home Products (P.) Ltd. v. Additional Commissioner of Income-tax	Notional rent cannot be taxed as Income from Other Sources where an agreement between sister concerns for sharing office premises was acted upon only for reimbursement of actual expenses.	Click Here	Income-tax Act, 1961
Section 57	Procter & Gamble Home Products (P.) Ltd. v. Additional Commissioner of Income-tax	Expenses incurred on letting out premises to a third party were remanded to restrict disallowance to depreciation and building-related expenses proportionate to the let-out area.	Click Here	Income-tax Act, 1961
Section 68	Prathamika Krishi Pattina Sahakari Sangh Niyamit v. Income-tax Officer	Specified Bank Notes deposited by a co-operative society from members during demonetization cannot be added as unexplained cash credit under section 68, as they were disclosed business receipts eligible for Section 80P deduction.	Click Here	Income-tax Act, 1961
Section 69A	Subba Rayudu Kalikiri v. Income-tax Officer	Addition under Section 69A read with 115BBE regarding cash rent source could not be made without the AO conducting a proper inquiry into the submitted affidavits and bank statements.	Click Here	Income-tax Act, 1961
Section 80G	ST. Josephs High School v. CIT (Exemption)	Rejection of approval under Section 80G solely based on refusal of Section 12AB registration is unsustainable without recording independent findings on Section 80G(5) conditions.	Click Here	Income-tax Act, 1961
Section 92C	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	For USD-denominated intercompany loans funded through internal accruals, LIBOR plus 80 basis points constitutes an appropriate benchmark rate rather than domestic borrowing rates.	Click Here	Income-tax Act, 1961
Section 92C	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	Where no primary TP adjustment survived for exclusivity fee and upfront discount, consequential notional interest adjustments imputed by treating them as interest-free advances could not be sustained.	Click Here	Income-tax Act, 1961
Section 92C	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	ALP of transition fees paid on a cost-to-cost basis for transfer of ongoing IT agreements cannot be determined at ‘nil’ without applying a prescribed transfer pricing method under section 92C read with Rule 10B.	Click Here	Income-tax Act, 1961
Section 148A	IBS Software (P.) Ltd. v. Union of India	Reassessment proceedings under section 148A(3) were quashed where the assessee demonstrated that the underlying amount for Marked to Market hedge reserve was already taxed in a prior year.	Click Here	Income-tax Act, 1961
Section 159	Kandhasamy Amaravathy v. Income-tax Officer	A section 148 reassessment notice issued in the name of a deceased assessee is invalid, requiring fresh notice to be served upon the legal representatives.	Click Here	Income-tax Act, 1961
Section 199	Tech Mahindra Ltd. v. Deputy Commissioner of Income-tax	Full TDS credit must be granted based on physical TDS certificates produced for years prior to the implementation of Form 26AS.	Click Here	Income-tax Act, 1961
Section 260A	Principal Director of Income-tax (Investigation) v. Prakash Nimmagadda	Departmental appeal before the High Court is non-maintainable where the tax effect on penalty under the Black Money Act is below the CBDT threshold limit of ₹2 crores.	Click Here	Income-tax Act, 1961 / Black Money Act