| Income-tax Act, 1961 |
Section 2(15) |
International Society for Krishna Consciousness v. Commissioner of Income-tax (Exemptions) |
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Examining income application, receipt quantum, and profitability during Section 12AB renewal exceeded CIT(E)’s jurisdiction, rendering rejection unsustainable. |
| Income-tax Act, 1961 |
Section 2(15) |
International Society for Krishna Consciousness v. Commissioner of Income-tax (Exemptions) |
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Proviso to Sec 2(15) was inapplicable as activities spanned multiple specific charitable limbs without fund diversion, making trust eligible for Sec 12AB registration. |
| Income-tax Act, 1961 |
Section 2(15) |
International Society for Krishna Consciousness v. Commissioner of Income-tax (Exemptions) |
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Denial of renewal based on commercial receipts exceeding 20% was incorrect since activities were run at minimal margin/cost without commercial orientation. |
| Income-tax Act, 1961 |
Section 11 |
Mewar University v. Income-tax Officer, Exemption |
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Specific direction corpus donations retain tax-exempt status even if the educational entity claimed exemption under Sec 10(23C)(vi) instead of Sec 11. |
| Income-tax Act, 1961 |
Section 12AB |
International Society for Krishna Consciousness v. Commissioner of Income-tax (Exemptions) |
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Presenting net figures in Income & Expenditure account while disclosing gross figures in schedules isn’t “incorrect information” or a violation under Sec 12AB(4). |
| Income-tax Act, 1961 |
Section 12AB |
Urban Improvement Trust v. Ward Exemption |
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CIT(E) must evaluate applicability of Rajasthan Public Trust Act exemptions before treating non-registration as non-compliance for Sec 12AB renewal. |
| Income-tax Act, 1961 |
Section 12AB |
Innovative Microfinance for Poverty Alleviation and Community Transformation v. CIT (Exemptions) |
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Rejection of fresh registration solely for delayed re-registration post object-deed amendment without assessing charitable eligibility was unjustified. |
| Income-tax Act, 1961 |
Section 14A |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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No disallowance under Section 14A read with Rule 8D can be made in a year where no exempt income was earned. |
| Income-tax Act, 1961 |
Section 28(i) |
Sri Balaji Shopping World v. Income-tax Officer |
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Addition based on gross Form 26AS receipts was invalid where assessee reconciled discrepancies caused by BSNL trade discounts without contradiction. |
| Income-tax Act, 1961 |
Section 35 |
Principal Commissioner of Income-tax v. Cadila Healthcare Ltd. |
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In-house R&D deduction under Sec 35(2AB) cannot be denied for delayed DSIR approval if the application preceded expenditure and purpose was genuine. |
| Income-tax Act, 1961 |
Section 36(1)(vii) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Irrecoverable service fees and interest previously offered to tax and subsequently written off in books are allowable as bad debts. |
| Income-tax Act, 1961 |
Section 36(2) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Written-off student receivables offered as income upon enrolment are allowable bad debts under Sec 36(1)(vii) read with 36(2); ad hoc disallowance is void. |
| Income-tax Act, 1961 |
Section 37(1) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Loan processing fees paid to banks for business credit lines partake the nature of interest under Sec 2(28A) and are deductible revenue expenditure. |
| Income-tax Act, 1961 |
Section 37(1) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Prior period expenses were rightly disallowed in absence of proof that liability accrued or crystallized during the relevant assessment year. |
| Income-tax Act, 1961 |
Section 40(a)(ia) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Entire expenditure was disallowable for non-TDS in period prior to AY 2015-16, as the relaxed 30% disallowance regime applies only prospectively. |
| Income-tax Act, 1961 |
Section 40(a)(ia) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Year-end provisions for unascertained liabilities subject to 30% self-disallowance without TDS were remanded for de novo factual verification. |
| Income-tax Act, 1961 |
Section 40(a)(ia) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Royalty paid to subsidiary without TDS is non-disallowable if payee included receipt in taxable income under second proviso to Sec 40(a)(ia)/201(1). |
| Income-tax Act, 1961 |
Section 40(a)(ia) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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For non-TDS on director commission provision paid next year, disallowance post-01.04.2015 is restricted strictly to 30% of expenditure. |
| Income-tax Act, 1961 |
Section 41(1) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Remission/cessation under Sec 41(1) cannot be invoked where liabilities were continued in books and settled in subsequent financial years. |
| Income-tax Act, 1961 |
Section 41(1) |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Reversing student fee write-backs where no prior tax deduction or benefit was claimed does not constitute taxable income under Sec 41(1) or Sec 28. |
| Income-tax Act, 1961 |
Section 56 |
C.L. Educate Ltd. v. Assistant Commissioner of Income-tax |
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Section 56(2)(viib) cannot tax share premium on non-cash allotment for business acquisition, as provision applies solely to monetary consideration. |
| Income-tax Act, 1961 |
Section 56 |
Principal CIT-1 v. Boppudi Logistics (P.) Ltd. |
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Group preference share acquisition at CA-valuated price cannot be arbitrarily rejected by AO by citing isolated NRI transactions outside statutory valuation rules. |
| Income-tax Act, 1961 |
Section 56 |
Principal CIT-1 v. Boppudi Logistics (P.) Ltd. |
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Valuation of unquoted preference shares backed by a valid Rule 11UA CA certificate forms a binding, valid basis under Sec 56(2)(viia). |
| Income-tax Act, 1961 |
Section 68 |
Ram Avtar Gupta v. Income-tax Officer |
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Addition for capital credit from inherited/gifted jewellery deleted as specific evidence was provided and portal technical errors hindered valuation upload. |
| Income-tax Act, 1961 |
Section 68 |
Ram Avtar Gupta v. Income-tax Officer |
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Section 68 applies to any book credit including precious items introduced in kind, without specific exemptions for personal assets. |
| Income-tax Act, 1961 |
Section 69 |
Principal CIT-Central v. Uttam Chand Rakesh Kumar |
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Section 69 and higher Section 115BBE tax rates cannot be applied without explicit findings of unaccounted assets or unexplained investments. |
| Income-tax Act, 1961 |
Section 80G |
Innovative Microfinance for Poverty Alleviation and Community Transformation v. CIT (Exemptions) |
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Section 80G rejection appeal was remitted back alongside Sec 12A proceedings since approval under 80G is strictly consequential to 12A registration. |
| Income-tax Act, 1961 |
Section 80G |
International Society for Krishna Consciousness v. Commissioner of Income-tax (Exemptions) |
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Renewal under Sec 80G(5)(ii) must be granted as a consequential outcome once Sec 12AB denial is set aside with directions to grant registration. |
| Income-tax Act, 1961 |
Section 80G |
Radha Swami Satsang Dinod v. Commissioner of Income-tax (Exemption) |
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Sec 80G approval cannot be denied to a Sec 12AB registered trust for minor religious objects if religious spending remains within permissible statutory limits. |
| Income-tax Act, 1961 |
Section 115BBE |
Dhukha Ram v. ACIT |
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Higher tax rate under Sec 115BBE cannot be applied to surrendered survey income without specific invocation and findings under Sec 68 to 69D. |
| Income-tax Act, 1961 |
Section 149 |
Satya Narayan Jha v. Principal Chief Commissioner of Income Tax Bihar and Jharkhand |
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Reassessment proceedings quashed and Bank fined Rs. 25,000 for wrong data triggering notice where actual deposit was Rs. 12.5 lakhs, below Sec 149 threshold. |
| Income-tax Act, 1961 |
Section 194LA |
Chalamala Narasa Reddy v. Special Deputy Collector LAO Somasila Project (LAO) |
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Compulsory acquisition compensation under RFCTLARR Act (excl. Sec 46) is income-tax exempt and free from Sec 194LA TDS deduction. |
| Income-tax Act, 1961 |
Section 201 |
SBI v. Income-tax Officer |
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Bank couldn’t be treated as assessee-in-default under Sec 201(1) for non-deduction of TDS on LFC reimbursement backed by a binding judicial restraint order. |
| Income-tax Act, 1961 |
Section 244A |
S.N. Agrawal v. Union of India |
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Interest under Sec 244A on refunded excess self-assessment tax post-appellate order is payable from the date of tax payment until actual refund. |
| Income-tax Act, 1961 |
Section 244A |
Vodafone Idea Ltd. v. Assistant Commissioner of Income-tax |
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Revenue cannot withhold vested appellate/Sec 201 refunds or delay interest by demanding Form 26B due to demands against sister TANs under Rule 31A. |
| Income-tax Act, 1961 |
Section 245 |
Vodafone Idea Ltd. v. Assistant Commissioner of Income-tax |
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Withholding quantified refunds with interest against demands without a formal order under Sec 245 is arbitrary and violates Articles 14, 19(1)(g) and 300A. |
| Income-tax Act, 1961 |
Section 253 |
SBI v. Income-tax Officer |
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Delay in filing appeal was condoned as lack of e-filing credentials and delayed order knowledge constituted sufficient cause. |
| Income-tax Act, 1961 |
Section 271C |
SBI v. Income-tax Officer |
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Penalty under Sec 271C cannot survive and must be deleted once the underlying Sec 201(1) order treating entity as assessee-in-default is quashed. |
