INCOME TAX CASE LAWS 28.07.2026

Relevant Act	Section	Case Law Title / Item Title	Brief Summary	Citation
Income-tax Act, 2025	Section 509, Rules 241-244	CBDT Guidance Note on Crypto-Asset Reporting	Explains reporting obligations for Crypto-Asset Service Providers (RCASPs), due diligence, compliance, and includes OECD-aligned CARF FAQs.	Click Here
Income-tax Act, 2025	Sections 247, 248	CBDT Notification on ITR-BN	Amends rules to insert Appendix IV prescribing ITR-BN for block assessment returns for searches initiated on or after April 1, 2026.	Click Here
Income-tax Act, 2025	Income-tax Act, 2025 & Rules 2026	CBDT Guidance Note on FATCA and CRS	Guidance on FATCA/CRS incorporating OECD’s 2025 amendments, providing 100 FAQs for Reporting Financial Institutions filing Form 166.	Click Here
Income-tax Act, 1961	Section 2(14)	Manoj Kumar Singh v. ITO	Matter restored to AO for fresh factual inquiry to resolve contradictory claims regarding whether the land was agricultural or a chargeable capital asset.	Click Here
Income-tax Act, 1961	Section 2(47)	Sathi Guha v. ITO	Mere execution of registered JDA without satisfying Section 53A of Transfer of Property Act does not amount to a transfer under Section 2(47)(v).	Click Here
Income-tax Act, 1961	Section 2(47)	Kondibai Kacharya Navadekar v. ITO	No transfer occurred under Section 2(47) as developer was not given possession and construction remained incomplete, with no monetary consideration received.	Click Here
Income-tax Act, 1961	Section 11	JCIT (OSD) v. S.M. Sehgal Foundation	Exemption under Sec 11/12 cannot be denied where property leasing is incidental to overall charitable activities and receipts are applied to charitable objects.	Click Here
Income-tax Act, 1961	Section 11	JCIT (OSD) v. S.M. Sehgal Foundation	Recognizing tied FCRA grants as income only when utilized for specific charitable purposes aligns with standard accounting principles and is valid.	Click Here
Income-tax Act, 1961	Section 12A	PCIT (Exemption) v. Shree Naminath Shwetamber Murtipujak Tapagachh Jain Religious Trust	Section 13(1)(b) cannot be invoked to deny initial registration under Section 12A; its applicability arises only at the assessment stage examining exemption.	Click Here
Income-tax Act, 1961	Section 13	JCIT (OSD) v. S.M. Sehgal Foundation	Remuneration paid to CEO for managing charitable programs cannot be disallowed/denied exemption absent evidence showing it was excessive or a income diversion.	Click Here
Income-tax Act, 1961	Section 14A	Sun Pharma Laboratories Ltd. v. DCIT	Disallowance under Section 14A/Rule 8D set aside in absence of change in facts/law when revenue consistently accepted favorable stance in earlier years.	Click Here
Income-tax Act, 1961	Section 14A	DCIT v. Deepak Nitrite Ltd.	Computation of Rule 8D disallowance using WDV of fixed assets & net current assets instead of total assets appearing in the balance sheet is unsustainable.	Click Here
Income-tax Act, 1961	Section 32	DCIT v. Deepak Nitrite Ltd.	Remaining 50% additional depreciation on plant/machinery used for <180 days in acquisition year is allowable in the immediately succeeding year.	Click Here
Income-tax Act, 1961	Section 35	DCIT v. Deepak Nitrite Ltd.	R&D expense rejection by DSIR for Sec 35(2AB) does not automatically disentitle deduction under Sec 35(1)(i)/35(1)(iv); matter remanded for AO’s independent review.	Click Here
Income-tax Act, 1961	Section 35	DCIT v. Deepak Nitrite Ltd.	For AY 2016-17, weighted deduction under Sec 35(2AB) cannot be restricted merely because DSIR certified a lower amount in Form 3CL than actually spent on valid facility.	Click Here
Income-tax Act, 1961	Section 35	DCIT v. Deepak Nitrite Ltd.	Post 01-07-2016 amendment to Rule 6(7A), DSIR is empowered to quantify eligible R&D expenditure, and Income-tax authorities cannot override DSIR quantification.	Click Here
Income-tax Act, 1961	Section 35	Deepak Nitrite Ltd. v. DCIT	Disallowance of weighted deduction under Sec 35(2AB) by DSIR does not auto-deny deduction under Sec 35(1)(i); matter remanded for fresh examination.	Click Here
Income-tax Act, 1961	Section 35	Deepak Nitrite Ltd. v. DCIT	AO directed to grant consequential relief if DSIR subsequently revises/enhances certified R&D expenditure in Form 3CL post-assessment completion.	Click Here
Income-tax Act, 1961	Section 45	Rajesh D Gaikawad v. ITO	No capital gains under Section 45 arise where registered JDA stipulated possession after encumbrance removal, and possession/commencement was not given in AY.	Click Here
Income-tax Act, 1961	Section 56	DCIT v. Nitin Kshirsagar (HUF)	Booking of flat via earnest money and allotment letter in 2001 constitutes an agreement to sell under Sec 56(2)(x)(b) proviso; deemed income addition on 2019 registration void.	Click Here
Income-tax Act, 1961	Section 56	ITO v. Jennis Pankajbhai Shah	Rejection of rectification by CIT(A) on incorrect factual premises regarding rural agricultural land status set aside; matter remanded to AO for fresh review.	Click Here
Income-tax Act, 1961	Section 69A	Rajesh D Gaikawad v. ITO	Reassessment additions for unexplained money set aside as credit card payments and investments were supported by banking channels and declared income.	Click Here
Income-tax Act, 1961	Section 69A	Clarion Agro Products (P.) Ltd. v. ACIT	Addition of unrecorded excess cash found during search in MD chamber/cashier upheld as explanation of villa advance refund lacked credible evidence.	Click Here
Income-tax Act, 1961	Section 69A	Clarion Agro Products (P.) Ltd. v. ACIT	CIT(A) correcting the statutory section to 69A without altering facts, quantum, or basis is valid and does not violate principles of natural justice.	Click Here
Income-tax Act, 1961	Section 69C	Clarion Agro Products (P.) Ltd. v. ACIT	Minor physical stock shortage detected during search required fresh adjudication as oral claims of manufacturing wastage lacked quantitative/scientific proof.	Click Here
Income-tax Act, 1961	Section 80-IE	Sun Pharma Laboratories Ltd. v. DCIT	Deduction under Sec 80-IE for Sikkim pharmaceutical unit upheld as issue of splitting up business/old machinery was already decided in assessee’s favor in past AYs.	Click Here
Income-tax Act, 1961	Section 115JB	Sun Pharma Laboratories Ltd. v. DCIT	Disallowance of depreciation/amortization of intangibles while computing MAT book profit unjustified, following earlier favorable ITAT orders.	Click Here
Income-tax Act, 1961	Section 115JB	Sun Pharma Laboratories Ltd. v. DCIT	Transfers to Debenture Redemption Reserve (per Companies Act) represent provisions for ascertained liabilities, not reserves; MAT book profit recomputation allowed.	Click Here
Income-tax Act, 1961	Section 127	Manmohan Das Kurre v. ITO	Reassessment framed after shifting jurisdiction without a valid transfer order passed under Section 127 by a competent authority is illegal and void.	Click Here
Income-tax Act, 1961	Section 144B	KEM Hospital & Seth G. S. Medical College Co-op Credit Soc. v. NFAC	Final assessment order quashed for natural justice violation where AO made enhancements beyond the proposed amount in the show-cause notice without notice.	Click Here
Income-tax Act, 1961	Section 148	Manmohan Das Kurre v. ITO	Reassessment completed by an officer who did not issue the original notice under Section 148 (without fresh notice) is invalid and lacks jurisdiction.	Click Here
Income-tax Act, 1961	Section 151	PCIT v. Wudstay Travels (P.) Ltd.	Reassessment initiated beyond 3 years with approval from PCIT instead of PCCIT (competent authority) under Section 151 is invalid and unsustainable.	Click Here
Income-tax Act, 1961	Section 151	Damanjeet Singh Oberoi v. DCIT	Reassessment notice & order under 148A(d) issued beyond 3 years approved by PCIT instead of PCCIT/CCIT as per Sec 151(ii) render assessment void ab initio.	Click Here
Income-tax Act, 1961	Section 153D	Clarion Agro Products (P.) Ltd. v. ACIT	Section 153D search assessment approval not invalidated by minor clerical defects, lack of DIN, or advisory remarks, in view of saving provisions of Section 292BC.	Click Here
Income-tax Act, 1961	Section 192	SBI Coimbatore Branch v. ACIT, TDS	Bank non-deduction of TDS on employee foreign LTC based on High Court interim stay doesn’t make bank an assessee in default retroactively after SC final order.	Click Here
Income-tax Act, 1961	Section 271C	Jagdish Prasad Singhania v. Addl. CIT (TDS)	Penalty for non-deduction of TDS quashed due to an unexplained delay of 18 months in issuing penalty notice by Additional CIT after assessment.	Click Here