taxheal income tax case laws Archives - Tax Heal

INCOME TAX CASE LAWS 22.07.2026

CA Satbir Singh — Fri, 24 Jul 2026 06:14:02 +0000

INCOME TAX CASE LAWS 22.07.2026

Section	Case Law Title	Brief Summary	Citation	Relevant Act
Section 2(14)	Sonu Grover v. Income-tax Officer	Verification of actual distance from municipal limits using Tehsildar’s certificate and Google Maps was required to determine whether land sold was a rural agricultural land exempt from capital gains; matter remanded for fresh adjudication.	Click Here	Income-tax Act, 1961
Section 2(15)	Masina Hospital Trust v. CIT (Exemptions)	Where a charitable hospital had no evidence of income diversion for private benefit, metrics like tariff or revenue per bed alone could not make its activities commercial; entitled to Section 12AB renewal.	Click Here	Income-tax Act, 1961
Section 2(15)	Commissioner of Income-tax (Exemptions) v. Salej Rotary Seva Foundation	Registration under Section 12AB was justified for a Section 8 company since its main objects were not limited to members and welfare activities benefited the public at large.	Click Here	Income-tax Act, 1961
Section 10(23)	ITO (E) v. Board of Control for Cricket in India	PILCOM was a joint managing committee and not an independent AOP; hence, only BCCI’s Indian match surplus from the 1996 World Cup was assessable, with Section 10(23) exemption allowable.	Click Here	Income-tax Act, 1961
Section 11	Nizamia Hyderabad Womens Association Trust v. Income-tax Officer	Excess application of income entitlement flows directly from Section 11 and cannot be denied merely because a separate carry-forward claim was not made in earlier returns.	Click Here	Income-tax Act, 1961
Section 12AB	Ashoka University v. Commissioner of Income-tax (Exemption)	Section 12AB renewal could not be denied based on unsupported allegations or differing interpretations without findings of non-genuine activities by relevant authorities.	Click Here	Income-tax Act, 1961
Section 12AB	Ashoka University v. Commissioner of Income-tax (Exemption)	Rejection of a renewal application cannot automatically act as a cancellation of existing registration without initiating statutory cancellation proceedings under Section 12AB(4).	Click Here	Income-tax Act, 1961
Section 12AB	D.R. Shanmukappa Charitable Trust v. Commissioner of Income-tax (Exemptions)	Rejection of earlier applications for procedural defects does not bar a trust from filing a fresh Section 12AB application, which can be granted prospectively from the new application date.	Click Here	Income-tax Act, 1961
Section 12AB	Masina Hospital Trust v. CIT (Exemptions)	Renewal proceedings under Section 12AB cannot be converted into a retrospective cancellation/annulment of existing registration from the date of grant without findings of fraud or statutory violations.	Click Here	Income-tax Act, 1961
Section 12AB	Masina Hospital Trust v. CIT (Exemptions)	Independent cancellation of Section 12AB registration for alleged non-compliance with the Maharashtra Public Trusts Act (Indigent Patients’ Fund) was unjustified without an adverse finding from authorities under that Act.	Click Here	Income-tax Act, 1961
Section 12AB	Ahmedabad Visha Shrimali Jain v. CIT (Exemption)	Subsisting registration in Form 10AC could not be treated as invalid or rejected solely for non-production of an earlier certificate where no adverse findings existed regarding trust objects or activities.	Click Here	Income-tax Act, 1961
Section 12AB	Ahmedabad Visha Shrimali Jain v. CIT (Exemption)	Matter restored for limited verification after the trust produced the prior registration certificate, confirming that renewal should not be rejected merely due to initial non-production.	Click Here	Income-tax Act, 1961
Section 14A	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Disallowance under Section 14A read with Rule 8D required fresh examination where interest-free funds exceeded investments and investments were made in growth funds not yielding exempt income.	Click Here	Income-tax Act, 1961
Section 32	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Balance 50% additional depreciation is allowable in the immediately succeeding assessment year if new plant/machinery was used for less than 180 days in the initial previous year.	Click Here	Income-tax Act, 1961
Section 37(1)	Patanjali Renewable Energy (P.) Ltd. v. Dy. CIT	Unclaimed input VAT credit included as part of purchase cost (and not claimed separately in VAT returns) is allowable as business expenditure under Section 37(1).	Click Here	Income-tax Act, 1961
Section 48	Sonu Grover v. Income-tax Officer	Recomputation of capital gains was ordered to grant indexation benefit on the sale of property.	Click Here	Income-tax Act, 1961
Section 48	Ranjan Sen Jain v. Income-tax Officer	AO could not replace registered valuers’ FMV and builder’s cost certificate with his own estimates without a reference to DVO; FMV and cost certificate should be accepted with proper Section 54 deduction.	Click Here	Income-tax Act, 1961
Section 54	Ranjan Sen Jain v. Income-tax Officer	Receiving multiple floors as a single residential unit under a collaboration agreement qualifies as acquiring one residential unit, making it eligible for Section 54 deduction.	Click Here	Income-tax Act, 1961
Section 54	Sonu Grover v. Income-tax Officer	Section 54 deduction is allowable where evidence (bank certificate/statement) establishes that unutilized capital gains were deposited in the Capital Gains Accounts Scheme.	Click Here	Income-tax Act, 1961
Section 54	Pavan Kumar Agarwal v. Deputy Commissioner of Income-tax	Restricting Section 54 exemption to only one house was improper where the assessee sold 17 flats and invested capital gains into 5 residential houses (exemption allowed up to the number of original properties transferred).	Click Here	Income-tax Act, 1961
Section 54F	Smt. Anuradha Chennu v. Dy. CIT	Prior to the Finance Act 2014 amendment, investment of consideration received via a JDA into multiple (50) flats was eligible for Section 54F exemption across all flats.	Click Here	Income-tax Act, 1961
Section 68	Patanjali Renewable Energy (P.) Ltd. v. Dy. CIT	Where cash deposits during demonetization showed a disproportionate spike prior to the period, a reasonable lump-sum addition was held proper instead of full disbelief/addition.	Click Here	Income-tax Act, 1961
Section 68	Patanjali Renewable Energy (P.) Ltd. v. Dy. CIT	Submitting creditor’s confirmation and ledger account discharges the initial onus under Section 68; addition for unexplained credit deleted.	Click Here	Income-tax Act, 1961
Section 68	Prasad Nimmagadda v. ACIT	Assessee was granted another opportunity to present evidence regarding foreign bank credits before CIT(A) in the interest of justice given pending criminal proceedings.	Click Here	Income-tax Act, 1961
Section 72	Patanjali Renewable Energy (P.) Ltd. v. Dy. CIT	Assessing Officer must verify and compute brought-forward business loss before disallowing its set-off against subsequent year’s income.	Click Here	Income-tax Act, 1961
Section 92C	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Transfer pricing adjustment on royalty paid to AE deleted as TPO failed to bring any comparable uncontrolled transaction or benchmarking analysis on record.	Click Here	Income-tax Act, 1961
Section 92C	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Rejection of TNMM in favor of CUP using domestic sales without making adjustments for export market conditions was unjustified.	Click Here	Income-tax Act, 1961
Section 92C	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Benchmarking for delayed AE receivables should be calculated using LIBOR + 100 bps after granting a credit period, rather than SBI Prime Lending/Base Rate.	Click Here	Income-tax Act, 1961
Section 115-O	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Issue regarding whether Dividend Distribution Tax (DDT) rate is restricted by DTAA treaty rates was restored to AO to await final outcome of pending Supreme Court proceedings.	Click Here	Income-tax Act, 1961
Section 145A	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Deletion of additions on unutilized Modvat/Cenvat credit upheld as switching between inclusive and exclusive accounting methods was revenue neutral.	Click Here	Income-tax Act, 1961
Section 149	Jitendra Shankarlal Mistri v. Income-tax Officer	Section 148 reopening notice is valid if initial information suggested escapement of ≥ ₹50 lakhs, even if the final assessed escaped income turns out to be below ₹50 lakhs.	Click Here	Income-tax Act, 1961
Section 192	Kansai Nerolac Paints Ltd. v. Deputy Commissioner of Income-tax	Disallowance under Section 40(a)(ia) for director commission provision deleted because TDS was subsequently deducted under Section 192 upon payment.	Click Here	Income-tax Act, 1961
Section 263	Hollis Vitrified (P.) Ltd. v. Principal Commissioner of Income-tax	Tribunal impermissibly relied on a subsequent assessment order passed under Section 143(3) r.w.s. 263 while deciding an appeal against PCIT’s invocation of Section 263 jurisdiction; order quashed.	Click Here	Income-tax Act, 1961

INCOME TAX CASE LAWS 21.07.2026

CA Satbir Singh — Thu, 23 Jul 2026 06:18:19 +0000

INCOME TAX CASE LAWS 21.07.2026

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Black Money Act, 2015	Section 2	Vijendra Kedia v. DDIT (Inv.) & ACIT	Click Here	Notice/assessment quashed as a Not Ordinarily Resident was not an ‘assessee’ under Section 2(2) at notice issuance.
Black Money Act, 2015	Section 10	Vijendra Kedia v. DDIT (Inv.) & ACIT	Click Here	Additions/penalties on foreign shares bought out of non-taxable Indian income were unsustainable due to wrong valuation.
Benami Property Act, 1988	Section 2	V. Viswanath Kamath v. V. Balakrishna Kamath	Click Here	Claiming mother was a name-lender in a joint property sale deed was not barred as a benami transaction under Section 3.
Income-tax Act, 1961	Section 5	Sterling Holiday Resorts Ltd. v. DCIT	Click Here	Deferral of vacation home sales revenue over entitlement period consistent with past practice was upheld.
Income-tax Act, 1961	Section 10(10B)	Ravikiran Damodar Kudade v. ITO	Click Here	Ex-gratia paid to BSNL VRS-2019 retirees constitutes capital-nature ‘Retrenchment Compensation’ and is fully tax-exempt.
Income-tax Act, 1961	Section 12AB	Lodha Park Jain Sangh v. ITO (C)	Click Here	Rejection of trust registration for picking the wrong clause in Form 10AB is a curable procedural error requiring re-evaluation on merits.
Income-tax Act, 1961	Section 14A	ACIT v. JSW Steel Ltd.	Click Here	No interest disallowance under Rule 8D(2)(ii) when interest-free funds suffice; Section 14A disallowance cannot be added to Section 115JB book profit.
Income-tax Act, 1961	Section 14A	Mahindra and Mahindra Financial Services Ltd. v. DCIT	Click Here	Rule 8D applies prospectively from AY 2008-09; prior years require disallowance on a reasonable basis.
Income-tax Act, 1961	Section 28(i)	ACIT v. JSW Steel Ltd.	Click Here	NPV gain on pre-payment of deferred sales tax liability is a non-taxable capital receipt and excluded from Section 115JB book profit.
Income-tax Act, 1961	Section 28(iv)	ACIT v. JSW Steel Ltd.	Click Here	Write-back of project creditors related to asset acquisition does not trigger income under Section 41(1) or Section 28(iv).
Income-tax Act, 1961	Section 32	Mahindra and Mahindra Financial Services Ltd. v. DCIT	Click Here	Uninterruptible Power Supply (UPS) is part of a computer system qualifying for a 60% depreciation rate.
Income-tax Act, 1961	Section 36(1)(vii)	ACIT v. JSW Steel Ltd.	Click Here	Unrecovered property advances were not deductible as bad debts/business expenditure without showing integral connection to ordinary business operations.
Income-tax Act, 1961	Section 36(1)(vii)	ACIT v. JSW Steel Ltd.	Click Here	Write-off of business loans/interest to overseas subsidiaries previously offered to tax is deductible as bad debt or business loss.
Income-tax Act, 1961	Section 36(1)(vii)	ACIT v. JSW Steel Ltd.	Click Here	Unrecovered security deposits for leased business premises written off post-arbitration are allowable as bad debt or business loss.
Income-tax Act, 1961	Section 37	DCIT v. Polycab India Ltd.	Click Here	Consultancy disallowance supported by invoices/TDS cannot stand on retracted statements or unverified loose papers.
Income-tax Act, 1961	Section 37(1)	ACIT v. JSW Steel Ltd.	Click Here	CIT(A) properly entertained ESOP deduction claims made via revised computation without a revised tax return.
Income-tax Act, 1961	Section 37(1)	Mahindra and Mahindra Financial Services Ltd. v. DCIT	Click Here	Commission/brokerage paid to non-responding parties under Section 133(6) can be disallowed, but not without initiating an inquiry first.
Income-tax Act, 1961	Section 37(1)	Sterling Holiday Resorts Ltd. v. DCIT	Click Here	ESOP expenses claimed upon option exercise are non-contingent and allowable as business expenditure.
Income-tax Act, 1961	Section 37(1)	Sterling Holiday Resorts Ltd. v. DCIT	Click Here	Prior-period expense claim remanded to AO due to lack of verification on whether expenses crystallized during the year.
Income-tax Act, 1961	Section 45	ACIT v. JSW Steel Ltd.	Click Here	Capital reduction in overseas subsidiaries resulting in share extinguishment yields an allowable capital loss (or business loss).
Income-tax Act, 1961	Section 50C	Bhupendra Abhimanyu Kukreja v. ITO	Click Here	Recomputation of capital gains must adopt DVO valuation over stamp duty value when referenced under Section 50C(2).
Income-tax Act, 1961	Section 50C	Bhupendra Abhimanyu Kukreja v. ITO	Click Here	No Section 50C addition is warranted if the variation between sale price and DVO’s unrealistic hypothetical model is under 15%.
Income-tax Act, 1961	Section 68	DCIT v. Polycab India Ltd.	Click Here	Profit additions for unaccounted sales based solely on third-party statements/WhatsApp chats without stock/cash discrepancies were deleted.
Income-tax Act, 1961	Section 68	DCIT v. Polycab India Ltd.	Click Here	Post-search cash sales additions deleted as parallel records/third-party retractions lacked corroborative physical/independent evidence.
Income-tax Act, 1961	Section 68	Pahwa Buildtech (P.) Ltd. v. CIT(A)	Click Here	Share application money supported by ITR/bank details discharged onus; proof of ‘source of source’ was not required for AY 2011-12.
Income-tax Act, 1961	Section 68	Pahwa Buildtech (P.) Ltd. v. CIT(A)	Click Here	Unsecured loans repaid via banking channels and backed by lender creditworthiness details cannot be treated as unexplained cash credits.
Income-tax Act, 1961	Section 69A	DCIT v. Polycab India Ltd.	Click Here	Additions based solely on loose sheets found at an employee’s home without cash/asset nexus to the assessee are unsustainable.
Income-tax Act, 1961	Section 69C	DCIT v. Polycab India Ltd.	Click Here	Unexplained land purchase expenditure estimated uniformly at 20% on-money based on generic statements was set aside.
Income-tax Act, 1961	Section 69C	DCIT v. Polycab India Ltd.	Click Here	Additions relying on employee loose sheets and retracted statements without recipient details failed Section 69C conditions.
Income-tax Act, 1961	Section 69C	DCIT v. Polycab India Ltd.	Click Here	Uniform extrapolation of alleged cash salary expenses across multiple years based on retracted statements was deleted.
Income-tax Act, 1961	Section 69C	ACIT v. JSW Steel Ltd.	Click Here	Section 69C additions relying on untested third-party statements without cross-examination opportunities were deleted.
Income-tax Act, 1961	Section 72A	Sterling Holiday Resorts Ltd. v. DCIT	Click Here	Set-off/carry-forward of losses disallowed as demerger share allotment by a holding company violated Sections 2(19AA)(iv) and 2(41A).
Income-tax Act, 1961	Section 92C	ACIT v. JSW Steel Ltd.	Click Here	State electricity board tariff for industrial consumers accepted as CUP for captive power transfers.
Income-tax Act, 1961	Section 92C	ACIT v. JSW Steel Ltd.	Click Here	Foreign currency loan interest benchmarked via Thomson Reuters LPC (CUP) upheld over TPO’s Bloomberg LIBOR-plus approach.
Income-tax Act, 1961	Section 92C	ACIT v. JSW Steel Ltd.	Click Here	Corporate guarantee commission rate restricted to 0.35% (down from 2% proposed by TPO) per past precedent.
Income-tax Act, 1961	Section 132B	Kamal Kumar Khetawat v. UOI	Click Here	Interest @ 0.5%/month payable on refunded seized cash after 120 days from search end, despite pending vigilance references.
Income-tax Act, 1961	Section 144B	Noel Villas and Apartments v. ACIT	Click Here	Skipping oral hearing didn’t violate natural justice when ‘Seek Video Conferencing’ option wasn’t opted for by the assessee.
Income-tax Act, 1961	Section 144B	Noel Villas and Apartments v. ACIT	Click Here	Partnership firm is not an eligible assessee under Section 144C(15)(b); issuing a draft assessment order was not mandatory.
Income-tax Act, 1961	Section 149	Madhav Power (P.) Ltd. v. ACIT	Click Here	Extended 10-year reopening limit includes the search AY; notices issued outside this block are time-barred.
Income-tax Act, 1961	Section 151	Konda Giri Goud v. ITO	Click Here	Reopening notice beyond 3 years quashed as sanction was obtained from PCIT instead of the higher authority required under Section 151(ii).
Income-tax Act, 1961	Section 153	Noel Villas and Apartments v. ACIT	Click Here	Assessment completed on 28.09.2022 was valid as the statutory deadline for AY 2020-21 was extended to 30.09.2022.
Income-tax Act, 1961	Section 270A	Mithibai College Employees Co-op Credit Soc. v. ITO	Click Here	Penalty for under-reporting/misreporting deleted as deduction denial was due to a PAN status glitch without proven misreporting.
Income-tax Act, 1961	Section 276CC	Rakesh Bhailalbhai Gandhi v. ITO	Click Here	Prosecution against an ex-director for non-filing of tax return quashed as he resigned before FY end and return due date.

INCOME TAX CASE LAWS 20.07.2026

CA Satbir Singh — Wed, 22 Jul 2026 09:41:09 +0000

INCOME TAX CASE LAWS 20.07.2026

Here is the structured summary of the notifications and judicial precedents organized by Section, Case Title, Brief Summary, Citation, and Relevant Act.

Relevant Act	Section / Rule	Case Title / Authority	Citation / Ref. No.	Brief Summary
Income-tax Act, 2025	Sec 2(112)	CBDT Notification	Click Here	Notifies NaBFID’s 10-year Zero-Coupon Bond (issue size up to ₹20,000 crore, issued up to March 31, 2028) as an eligible zero-coupon bond.
Income-tax Act, 1961	Sec 47(viiaf)	CBDT Notification	Click Here	Grants tax-neutral status for the transfer of capital assets from NPCIL to ASHVINI under a Central Government-approved restructuring plan for FY 2025-26.
Income-tax Act, 1961	Sec 10(23FB), Sec 10(34)	Income-tax Officer v. India Infrastructure Fund	Click Here	Dividend income received by a SEBI-registered Venture Capital Fund from qualifying undertakings is exempt under Sec 10(23FB) or independently under Sec 10(34). Simultaneous claims under Sec 10(23FB), 10(34), and 10(35) are permissible.
Income-tax Act, 1961	Sec 10(35)	Income-tax Officer v. India Infrastructure Fund	Click Here	Dividend income earned by a Venture Capital Fund from deploying temporary surplus funds in liquid mutual fund units is exempt under Sec 10(35), despite enjoying benefits under Sec 10(23FB).
Income-tax Act, 1961	Sec 12A	Juba Jyoti Jubak Sangha v. CBDT	Click Here	CIT(E) improperly rejected condonation of delay for filing Form 10B audit report due to COVID-19; genuine hardship and circulars must be considered to condone delay and adjudicate exemption claims.
Income-tax Act, 1961	Sec 12AB	Tulsi Eye Hospital v. Exem Ward 2(4)	Click Here	Renewal of trust registration under Sec 12AB cannot be denied solely because FCRA renewal was rejected without independently examining the trust’s objects, activities, and nexus.
Income-tax Act, 1961	Sec 12AB	Shri Vagad Visha Oswal Murtipujak Jain Sangh v. CIT (Exemptions)	Click Here	While adjudicating a Sec 12AB renewal application, CIT(E) lacks the authority to declare prior Sec 12AA registration invalid. Natural justice also requires prior specific notice before rejecting an application for lack of a self-certified copy of an old certificate.
Income-tax Act, 1961	Sec 14A r.w. Rule 8D	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Sec 14A disallowance cannot be invoked if the assessee did not earn any exempt income during the relevant financial year.
Income-tax Act, 1961	Sec 14A r.w. Rule 8D	Paradip Port Authority v. DCIT	Click Here	Where an assessee has a large investment portfolio but earns exempt income from only specific bonds, Sec 14A disallowance must be restricted to the average value of investments that actually yielded exempt income.
ITAT Rules, 1963	Rule 24	Gudari Large Sized Multipurpose Co-operative Society Ltd. v. Pr. CCIT	Click Here	Dismissal of an appeal solely because the Authorized Representative was not in proper dress during a virtual hearing is non-sustainable; the appeal was restored to be heard on merits.
Income-tax Act, 1961	Sec 36(1)(iv)	Paradip Port Authority v. DCIT	Click Here	A one-time contribution to cover an actuarially certified deficit in an approved superannuation/pension fund is fully deductible; Rule 87 ceiling does not apply to deficit contributions.
Income-tax Act, 1961	Sec 36(1)(va), Sec 271(1)(c)	BSC C & C Joint Venture v. ACIT/DCIT	Click Here	Penalty under Sec 271(1)(c) for delayed deposit of employees’ PF contribution is invalid if the AO failed to record proper satisfaction prior to initiating penalty proceedings.
Income-tax Act, 1961	Sec 37(1)	Paradip Port Authority v. DCIT	Click Here	Disallowance of software expenses cannot be sustained merely because the payee failed to respond to Sec 133(6) or was struck off, provided genuine transactions/invoices/TDS exist. Also holds that CSR expenses incurred by non-corporate statutory bodies and audited recurring provisions for accrued liabilities are allowable.
Income-tax Act, 1961	Sec 37(1)	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Interest paid under Sec 7Q of the EPF Act for delayed remittance is compensatory and deductible under Sec 37(1), whereas damages under Sec 14B are penal and non-deductible.
Income-tax Act, 1961	Sec 43B	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Where a provision for sick leave previously disallowed under Sec 43B is written back into income, AO must verify past disallowance and grant corresponding relief.
Income-tax Act, 1961	Sec 56, Rule 11UA	Geomysore Services (India) (P.) Ltd. v. ITO	Click Here	If a DCF valuation report for share premium has defects, the AO cannot forcibly replace it with the NAV method; the AO must obtain a fresh valuation report from an approved valuer using the DCF method.
Income-tax Act, 1961	Sec 68	DCIT v. Pinkiben Riddheshkumar Bhandari	Click Here	Additions for LTCG on share sales as accommodation entries cannot be sustained under Sec 68 when bank statements, broker notes, and valid sales prove genuine transactions with no price-rigging evidence.
Income-tax Act, 1961	Sec 80-IA, Sec 80A(2)	Bajaj Energy (P.) Ltd. v. ACIT	Click Here	Sec 80-IA deduction is allowable up to the Gross Total Income (subject to Sec 80A(2)) and is not restricted merely to the heads of business income.
Income-tax Act, 1961	Sec 89	Ram Dattatray Kaldate v. ITO	Click Here	Settlement amounts received by an ex-employee under a voluntary retirement scheme after plant closure constitute a non-taxable capital receipt since there was no forced termination of employment.
Income-tax Act, 1961	Sec 115BAC	Balshiram Dattatray Thorat v. ITO	Click Here	A minor clerical error in mentioning the first opted year in the return does not invalidate eligibility under the new tax regime (Sec 115BAC) if Form 10-IE was validly submitted earlier and never withdrawn.
Income-tax Act, 1961	Sec 115JB	Pushkar Chemical and Fertilisers Ltd. v. DCIT	Click Here	A capital subsidy (Nutrient Based Subsidy) exempt under normal provisions must be excluded from book profits for MAT computation under Sec 115JB.
Income-tax Act, 1961	Sec 127	MS Agarwal Foundries (P.) Ltd. v. DCIT	Click Here	Prior notice or hearing is not mandatory for intra-city transfer of cases between Assessing Officers under Sec 127.
Income-tax Act, 1961	Sec 151, Sec 148	India Land Ventures Ltd. v. DCIT (Int’l Tax)	Click Here	Sanction for issuing a Sec 148 notice after three years granted by a Principal Commissioner instead of the Chief Commissioner renders the reassessment proceedings void for lack of jurisdiction.
Income-tax Act, 1961	Sec 153C	Pankajkumar Kanaiyalal Soni v. ITO	Click Here	Reassessment under Sec 153C based on seized digital material is barred by limitation if the assessment year falls beyond the permissible 10-year limit from the date the material is received by the jurisdictional AO.
Income-tax Act, 1961	Sec 154	Pushkar Chemical and Fertilisers Ltd. v. DCIT	Click Here	Settlement under DTVSV does not erase original orders; hence, the limitation period under Sec 154(7) for rectification must be calculated from the original reassessment order date.
Income-tax Act, 1961	Sec 199, Sec 194Q	Bhandari Bros v. ITO	Click Here	A commission agent (Kaccha Arahtia) is entitled to TDS credit reflected under his PAN, even if deducted erroneously by purchasers, as long as the tax has been deposited in the Government Treasury.

INCOME TAX CASE LAW DIGEST 16.06.2026

CA Satbir Singh — Sat, 18 Jul 2026 05:58:54 +0000

INCOME TAX CASE LAW DIGEST 16.06.2026

Relevant Act	Section	Case Law Title	Brief Summary	Citation
Income Tax Act, 1961	Section 11	National Academy of Agricultural Sciences v. Income-tax Officer	Receipts from providing commercial conference and auditorium facilities are not incidental to charitable objects and constitute taxable business income under Section 11(4A).	$2026$ Click Here
Income Tax Act, 1961	Section 11	National Academy of Agricultural Sciences v. Income-tax Officer	Administrative salaries paid to scientists and publication/printing expenses are incidental to the trust’s specific objects, qualifying as valid application and accumulation of income.	$2026$ Click Here
Income Tax Act, 1961	Section 14A	ACIT v. Reliance Industrial Investments and Holdings Ltd.	Disallowance under Rule 8D is unsustainable if the Assessing Officer (AO) fails to record objective dissatisfaction regarding the assessee’s suo motu disallowance computation.	$2026$ Click Here
Income Tax Act, 1961	Section 115JB	ACIT v. Reliance Industrial Investments and Holdings Ltd.	Convertible debentures comprising only equity without liability components cannot be treated as transition amounts to increase book profits under Section 115JB(2C) for MAT purposes.	$2026$ Click Here
Income Tax Act, 1961	Section 115WB	MRF Ltd. v. Deputy Commissioner of Income-tax	Employee medical reimbursements up to ₹15,000 per annum (exempt as perquisites for employees) do not attract Fringe Benefit Tax (FBT) in the hands of the employer.	$2026$ Click Here
Income Tax Act, 1961	Section 144	Sanjay Mahendrabhai Desai v. National e-Assessment Centre Assessment Unit	A faceless best judgment assessment order passed without granting a requested video conference hearing or a meaningful response window violates natural justice and is invalid.	$2026$ Click Here
Income Tax Act, 1961	Section 145	Isha Metal Stores v. Assistant Commissioner of Income-tax	The Assessing Officer cannot estimate the gross profit on unrecorded sales without explicitly rejecting the regular books of account under Section 145(3) or invoking Section 144.	$2026$ Click Here
Income Tax Act, 1961	Section 145	Navjeet Singh Bhatia v. Income-tax Officer	Estimating a higher gross profit (4%) for a liquor trader is unjustified when a comparable trader’s lower GP rate (3.13%) has already been accepted by the Revenue.	$2026$ Click Here
Income Tax Act, 1961	Section 145	Navjeet Singh Bhatia v. Income-tax Officer	Once the books of account are rejected and the gross profit is estimated by the AO, no further ad-hoc disallowance of P&L expenses can be legally sustained.	$2026$ Click Here
Income Tax Act, 1961	Section 147A	Income-tax Officer v. Sai Kumar Mateti	Reassessment notices for AY 2015-16 fail based on the Apex Court’s concession in Rajeev Bansal; remaining ambiguous matters are remanded back to respective High Courts.	$2026$ Click Here
Income Tax Act, 1961	Section 153A	ACIT v. Honey Arora	If no search warrant or panchnama is drawn up specifically in the name of the assessee, the assumption of jurisdiction and assessments framed under Section 153A are void.	$2026$ Click Here
Income Tax Act, 1961	Section 220	Cashfree Payments India (P.) Ltd. v. Principal Commissioner of Income-tax	Recovering a full tax demand despite an interim stay and failing to give a fair hearing on a pre-deposit waiver warrants a remand and refund of excess collections.	$2026$ Click Here
Income Tax Act, 1961	Section 254	Principal Commissioner of Income-tax v. Taha Wires (P.) Ltd.	The ITAT cannot dismiss a Department appeal involving a law enforcement agency (like DGCEI) on low tax effects, as such cases fall under exceptions to CBDT circulars.	$2026$ Click Here
Income Tax Act, 1961	Section 254	ACIT v. Rolls Royce India (P.) Ltd.	The Supreme Court’s Covid-19 exclusion period for limitation applies strictly to judicial/quasi-judicial proceedings, not to standard assessment time bounds.	$2026$ Click Here

INCOME TAX CASE LAWS 16.07.2026

CA Satbir Singh — Fri, 17 Jul 2026 05:51:12 +0000

INCOME TAX CASE LAWS 16.07.2026

Here is the structured summary of the case laws compiled into a clean, scannable table for your reference.

Relevant Act	Section	Case Law Title	Citation	Brief Summary
Income-tax Act, 1961	Section 2(14)	Superb Infotech (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Profit from the sale of rural agricultural land (beyond municipal limits/not a capital asset) sold in a single transaction cannot be taxed as business income or capital gains. Subsequent non-agricultural use by the buyer is irrelevant to the seller’s tax liability.
Prohibition of Benami Property Transactions Act, 1988	Section 4	Braham Dev Sood v. Janki	$2026$ Click Here	Section 4 bars the enforcement of any right in benami property (including protection of possession) in suits filed after the Act’s enactment, regardless of when the transaction occurred (even if purchased in 1948-49).
Prohibition of Benami Property Transactions Act, 1988	Section 5	Braham Dev Sood v. Janki	$2026$ Click Here	Once a property is established as benami, neither the real purchaser nor the heirs of the original sellers can claim rights over it; the property is liable to central government acquisition without compensation.
Income-tax Act, 1961	Section 14A	HDFC ERGO General Insurance Company Ltd. v. Assistant Commissioner of Income-tax	$2025$ Click Here	Section 14A read with Rule 8D is not applicable for making disallowances of expenditure incurred in relation to exempt income for assessees engaged in insurance businesses computed under Section 44.
Income-tax Act, 1961	Section 14A	Poonawalla Fincorp Ltd. v. Income-tax Officer	$2026$ Click Here	No disallowance under Section 14A is warranted if no exempt income was earned during the year. The Finance Act 2022 amendment (applying disallowance even without exempt income) is prospective.
Income-tax Act, 1961	Section 37(1)	HDFC ERGO General Insurance Company Ltd. v. Assistant Commissioner of Income-tax	$2025$ Click Here	Payments made by a general insurer to aggregators for motor insurance policy servicing/support are allowable business expenditures if no Insurance Act offense or IRDAI guideline violation is established.
Income-tax Act, 1961	Section 45	Tejal Kaushik Maisheri v. Assistant Commissioner of Income-tax, Central	$2026$ Click Here	An amount of ₹50 lakhs received by the assessee and spouse, intrinsically linked to land acquisition activities of a buyer group, must be taxed as part of full value of consideration in the year of sale, not under Section 69A.
Income-tax Act, 1961	Section 56	VNG Automotive (P.) Ltd. v. Assistant Commissioner of Income-tax	$2026$ Click Here	Interest earned on temporary deposits of funds earmarked for setting up a plant/machinery and adjusted against pre-operative expenses is a capital receipt (not IFOS) to be set off or capitalized under Section 35D.
Income-tax Act, 1961	Section 69A	Superb Infotech (P.) Ltd. v. Deputy Commissioner of Income-tax	$2026$ Click Here	Section 153C proceedings initiated solely based on possession of partnership/dissolution deeds, without any incriminating material found during the search or link to undisclosed income, are unsustainable.
Income-tax Act, 1961	Section 147	VNG Automotive (P.) Ltd. v. Assistant Commissioner of Income-tax	$2026$ Click Here	Where an assessee adjusts interest from bank deposits against pre-operative expenses and the return was only processed under Section 143(1), assessment can be validly reopened under Section 147.
Income-tax Act, 1961	Section 148	Rudra Alloys (P.) Ltd. v. Assistant Commissioner of Income-tax	$2026$ Click Here	Notices issued under Section 148 by the Jurisdictional Assessing Officer (JAO) instead of the National Faceless Assessment Centre (NFAC) are without jurisdiction and liable to be set aside.
Income-tax Act, 1961	Section 149	Bipinkumar Girdharlal Parekh v. Office of the Assistant Commissioner of Income-tax	$2026$ Click Here	For searches conducted prior to the Finance (No. 2) Act, 2024, if the alleged escaped income is below ₹50 lakh, the 3-year limitation under Section 149(1)(a) applies, making notices issued beyond that period invalid.
Income-tax Act, 1961	Section 149	Bhavik Bhupendra Shah v. Assistant Commissioner of Income-tax	$2026$ Click Here	A notice under Section 148 for income escaping assessment relating to AY 2015-16 issued on or after April 1, 2021, is clearly time-barred and must be set aside.
Income-tax Act, 1961	Section 194A	Kavya Shaji v. Union of India	$2026$ Click Here	The TDS exemption under Section 194A(3)(ix) applies strictly to interest on the core MACT compensation award, not on the interest accumulated subsequent to depositing it in a bank fixed deposit.
Income-tax Act, 1961	Section 270A	Poonawalla Fincorp Ltd. v. Income-tax Officer	$2026$ Click Here	Imposition of penalty for under-reporting is unjustified if an NBFC claimed Education Cess deduction in good faith based on then-settled law, which was subsequently disallowed via retrospective amendment.