INCOME TAX CASE LAWS 30.09.20226

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Income-tax Act, 1961	Section 14A	Karur Vysya Bank Ltd. v. Commissioner of Income-tax-I	Click Here	Disallowance under Section 14A r.w. Rule 8D is unjustified for a banking company with sufficient surplus funds when no expenditure was actually incurred to earn exempt income.
Income-tax Act, 1961	Section 56	Income-tax Officer v. Fiero Fernandes	Click Here	Addition under Section 56 is unsustainable when the assessee’s apportioned share of the difference between actual consideration and stamp duty value is below the statutory threshold of Rs. 50,000.
Income-tax Act, 1961	Section 69	Income-tax Officer v. Fiero Fernandes	Click Here	Addition for unexplained investment under Section 69 cannot stand when joint property purchase consideration is fully evidenced through banking and loan channels.
Income-tax Act, 1961	Section 69A	Sanjeev Kumar Agarwal v. ACIT	Click Here	Digital ledger cash entries found during search cannot be treated as undisclosed investment of the assessee when the registered sale deed shows property purchase by another party.
Income-tax Act, 1961	Section 69A	Smt. Jaya Amitabh Bachchan v. Deputy Commissioner of Income-tax, Central	Click Here	Unexplained money addition under Section 69A based on unverified agreements, broker statements, and WhatsApp chats is liable to be deleted without reliable proof of actual receipt.
Income-tax Act, 1961	Section 69A	Smt. Jaya Amitabh Bachchan v. Deputy Commissioner of Income-tax, Central	Click Here	Bank credit received as advance during property sale negotiations is not unexplained money under Section 69A when payer identity, banking source, and nature of credit are fully established.
Income-tax Act, 1961	Section 69B	Urvara Agro (P.) Ltd. v. Income-tax Officer	Click Here	Reassessment initiated solely on an anonymous, unverified Tax Evasion Petition lacking tangible, credible evidence fails the statutory jurisdictional threshold and is invalid.
Income-tax Act, 1961	Section 80C	Rupeshkumar v. Income-tax Officer	Click Here	Ex parte dismissal of quantum appeal by CIT(A) for non-prosecution violates Section 250(6); matter restored to AO for adjudication on merits.
Income-tax Act, 1961	Section 80G	Jal Minocher Mistry Memorial Foundation v. Commissioner of Income-tax (Exemptions)	Click Here	Renewal application by a public charitable trust under clause (ii) of first proviso to Section 80G(5) is validly maintainable and must be examined on merits.
Income-tax Act, 1961	Section 143	Sanjeev Kumar Agarwal v. ACIT	Click Here	Reassessment completed under Sections 144/147 without serving mandatory notice under Section 143(2) after receiving return is invalid and quashed.
Income-tax Act, 1961	Section 147	JCIT (OSD) v. Ambay Construction Company	Click Here	Reassessment notice issued in the name of a dissolved partnership firm taken over by a company is void ab initio as Section 189 does not apply.
Income-tax Act, 1961	Section 148	Poonam Devi v. Income-tax Officer	Click Here	Notice under Section 148 served by affixture at a wrong address without adhering to Order V Rules 17 to 20 of CPC for substituted service is invalid.
Income-tax Act, 1961	Section 149	Ruhaan Shelters (P.) Ltd. v. Income-tax Officer	Click Here	Reassessment notice under Section 148 is unsustainable if the actual income embedded in gross receipts is under Rs. 50 lakhs, failing Section 149(1)(b) threshold.
Income-tax Act, 1961	Section 156	Dishnet Wireless Ltd. v. Union of India	Click Here	Income tax arrears not claimed by the Department during NCLT insolvency proceedings stand extinguished upon approval of the resolution plan.
Income-tax Act, 1961	Section 246A	Anya Traders v. Assessment Unit Income-tax Department	Click Here	SLP dismissed; High Court will not exercise writ jurisdiction under Article 226 against assessment orders when factual issues can be addressed through statutory appeals.
Income-tax Act, 1961	Section 271D	Divya Lok Co-Operative Group Housing Society Ltd. v. Income-tax Officer	Click Here	Penalty under Section 271D imposed by an Assessment Unit instead of the designated Penalty Unit (post-06.09.2022 SOP mandate) is without jurisdiction and bad in law.
Income-tax Act, 1961	Section 272A	Rupeshkumar v. Income-tax Officer	Click Here	Non-compliance with multiple Section 142(1) notices on the same issue constitutes a single default; penalties imposed for subsequent notices beyond the first are liable to be deleted.