INCOME TAX CASE LAWS 31.08.2026

CA Satbir Singh — Wed, 02 Sep 2026 08:13:29 +0000

INCOME TAX CASE LAWS 31.08.2026

Section	Case Law Title	Brief Summary	Citation	Relevant Act
Section 2(14) / Section 54B	Vasudev, Harsora v. ITA Dhar	Where assessee sold ancestral agricultural land and capital asset status/Section 54B claims lacked record evidence, ex parte appellate order was set aside and remanded for de novo consideration upon submission of complete documents.	Click Here	Income-tax Act, 1961
Section 10(10B)	Nanak Chand v. Income Tax Officer, Ward-1, Hisar	Compensation received by a retired BSNL employee under BSNL VRS-2019 was held to be retrenchment compensation under Section 10(10B) rather than Section 10(10C), making it eligible for exemption.	Click Here	Income-tax Act, 1961
Section 11 / Section 12	Jogniya Mata Shaktipith Vikas Sansthan v. Income Tax Officer	Exemption could not be denied for want of Section 12AA registration when the Tribunal had already directed the grant of such registration; matter remanded to give consequential effect.	Click Here	Income-tax Act, 1961
Section 12A / Section 12AB	Shree Mahaveer Swami Panchsikhri Jinalya Trust Kalani & Co LLP v. Commissioner of Income Tax Exemption	Form 10AB renewal could not be rejected on the technical ground of lacking registration prior to 01.04.2021 when the trust held a valid registration granted on 02.12.2022 and had no adverse findings on objects.	Click Here	Income-tax Act, 1961
Section 12AA	Jogniya Mata Shaktipith Vikas Sansthan v. Income Tax Officer	Where proceedings were a continuation of an original Form 10A application under Section 12AA, registration should have been granted under Section 12AA instead of Section 12AB with restricted validity.	Click Here	Income-tax Act, 1961
Section 32(1)	Hi-Tech Radiators (P.) Ltd. v. Deputy Commissioner of Income-tax	Excess consideration over net asset value in a slump sale recognized as goodwill was eligible for depreciation, as restrictions under sixth proviso to Section 32(1) apply only to amalgamations.	Click Here	Income-tax Act, 1961
Section 32(1) / Section 37(1)	Hi-Tech Radiators (P.) Ltd. v. Deputy Commissioner of Income-tax	Non-compete fees recognized in a slump sale cannot be capitalized to the intangible block for depreciation under Section 32; it is allowable only as revenue expenditure under Section 37(1).	Click Here	Income-tax Act, 1961
Section 37(1)	Principal Commissioner of Income-tax 3 v. Gujarat State Road Developement Corporation Ltd.	Project expenditure incurred wholly and exclusively for business in executing public infrastructure without grants cannot be disallowed merely because corresponding revenue was not recognized in that specific year.	Click Here	Income-tax Act, 1961
Section 54	Subh Karan Yadav v. Income-tax Officer	Exemption under Section 54 was denied because the residential plot was purchased and house constructed in the wife’s name; both sale and purchase must be executed by the same assessee under Section 2(7).	Click Here	Income-tax Act, 1961
Section 54F	Subh Karan Yadav v. Income-tax Officer	Section 54F relief is unavailable when the original transferred asset is itself a residential house, in addition to the new asset being acquired in the wife’s name.	Click Here	Income-tax Act, 1961
Section 54F	Vinodbhai Chhaganbhai Tamboli v. Deputy Commissioner of Income-tax	The cost of the new asset under Section 54F includes both the purchase price and subsequent expenditure on renovation/reconstruction required to make the residential house habitable.	Click Here	Income-tax Act, 1961
Section 69	Anita Bafna v. Income-tax Offficer	Unexplained investment must be assessed in the financial year the funds were actually paid/invested (FY 2017-18 via cheque), and cannot be shifted to a later year merely due to subsequent deed registration.	Click Here	Income-tax Act, 1961
Section 69A	Pradipkumar Vallabhdas Joisar v. Income-tax Officer	Reassessment based on a third-party complaint/loose note alleging cash transactions in a land dispute was quashed where the assessee had no ties to surveyed entities and no evidence supported cash exchange.	Click Here	Income-tax Act, 1961
Section 69C	Satpal Nandrajog v. Deputy Commissioner of Income-tax	Ex parte additions for cash payments and rent receipts were remanded for fresh adjudication after the assessee demonstrated inability to attend proceedings due to mental illness since 2011.	Click Here	Income-tax Act, 1961
Section 147	Satpal Nandrajog v. Deputy Commissioner of Income-tax	NaFAC validly assumed jurisdiction under Section 144B and relevant CBDT circulars to conduct faceless reassessments and pass orders under Section 147 read with Sections 144, 144B, 151A, and 147A.	Click Here	Income-tax Act, 1961
Section 147	Principal Commissioner of Income-tax (Central) v. NK Proteins (P.) Ltd.	Reassessment initiated beyond 4 years was quashed for lack of jurisdiction where the assessee had made full and true disclosure and no additions were ultimately made on the primary reopening reasons.	Click Here	Income-tax Act, 1961
Section 153A / Section 148	Krishna Mohan Potluri v. ACIT	Where the AO failed to initiate Section 153A proceedings within the limitation period following a Section 132A requisition, resorting to new Sections 148/148A was held impermissible and proceedings were quashed.	Click Here	Income-tax Act, 1961
Section 244A	Deputy Commissioner of Income-tax v. Bank of Baroda	When issuing tax refunds, the Revenue must adjust/appropriate the interest component first before applying payments toward principal tax to uphold time-value-of-money and prevent unjust enrichment.	Click Here	Income-tax Act, 1961
Section 245D(4A)	B.L. Agro Industries Ltd. v. Union of India	The 18-month statutory period under Section 245D(4A)(iii) is mandatory and runs from original allotment to the Interim Board; an administrative transfer does not extend limitation, rendering later orders void.	Click Here	Income-tax Act, 1961
Section 264	Sri Kaushik Narayan Bhattacharya v. Principal Commissioner of Income-tax	A revision petition under Section 264 is maintainable once the limitation period for filing an appeal has expired without an appeal being preferred or condonation sought.	Click Here	Income-tax Act, 1961
Section 271(1)(c)	Krishna Mohan Potluri v. ACIT	Where the substantive reassessment order making additions under Section 69A was quashed, the consequential penalty for concealment of income under Section 271(1)(c) could not survive.	Click Here	Income-tax Act, 1961
Section 272A(2)(e)	Swamy Vivekanandha Vidhyala Trust v. Income-tax Officer, Exemptions	Penalty for late filing of return by a trust can only run up to the outer time limit prescribed under Section 139(4), not up to the date of filing in response to a notice under Section 148.	Click Here	Income-tax Act, 1961

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INCOME TAX CASE LAWS 31.08.2026