IMPORTANT INCOME TAX CASE LAWS 07.06.2025 SECTION CASE LAW TITLE Brief Summary Citation Relevant Act 2(15) Kalanjiam Development Financial Services v. Income-tax Officer (Exemptions) Where the main objective of a trust is microfinance (lending operation), it is its main business and not incidental to a charitable object; hence, the trust cannot claim exemption u/s 11.… Read More »

Refund Under Vivad Se Vishwas Act Entitled to Interest Under Section 244A for Delayed Payment Issue: Whether an assessee, who has opted for and received a refund as part of a settlement under the Direct Tax Vivad Se Vishwas Act, 2020 (DTVSVA), is entitled to interest on the delayed payment of that refund under Section… Read More »

Section 149(1)(c) Retrospective Applicability for Foreign Assets: Referred to Larger Bench Due to Conflicting Interpretations and Unconsidered Explanation Issue: Whether Section 149(1)(c) of the Income-tax Act, 1961 (which allows for a longer limitation period for reopening assessments concerning foreign assets), introduced with effect from July 1, 2012, has retrospective operation, allowing for reopening of assessments… Read More »

Reopening Notice Issued After Original Limitation Period (Pre-Finance Act, 2021) is Without Jurisdiction Issue: Whether a reopening notice issued under Section 148 of the Income-tax Act, 1961, for Assessment Year 2013-14, on March 26, 2021, is valid, given that it was issued after the expiry of the period of limitation prescribed under Section 149(1)(a) and… Read More »

I. Search and Seizure Operation Quashed: No Valid “Reason to Believe” for Non-Production of Books/Documents Issue: Whether a search and seizure operation conducted under Section 132 of the Income-tax Act, 1961, at the premises of an assessee is legal and valid, when the “reason to believe” for such search is based merely on the assessee… Read More »

I. Allocation of Employee Benefit Expenses to Agricultural Activities Upheld Due to Nature of Work Issue: Whether the Assessing Officer (AO) was justified in allocating employee benefit expenses to agricultural activities on a proportionate basis, when the assessee claimed a much lower allocation, and the nature of the agricultural activity was specialized and labor-intensive. Facts:… Read More »

Section 80-IA(9): Deduction Under Other Chapter VI-A Provisions Not Restricted in Computation, Only in Final Allowability to Prevent Double Deduction Issue: How Section 80-IA(9) of the Income-tax Act, 1961, interacts with other deduction provisions under Heading ‘C’ of Chapter VI-A (which includes Section 80-HHC) when deduction under Section 80-IA is claimed, specifically whether it restricts… Read More »