SUPREME COURT
Case Title : THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) Vs ADANI WILMAR LIMITED
Case Number : SLP(C) 4944/2026
CITATION : 2026 LLBiz SC 35
The Supreme Court on Monday refused to interfere with a Gujarat High Court judgment that had quashed the reopening of Adani Wilmar Limited's income tax assessment for the 2013–14 assessment year, dismissing a special leave petition filed by the revenue. A Bench of Justice B. V. Nagarathna and Justice Ujjal Bhuyan said it was not inclined to step in after examining the record. “Having regard to the facts of this case, we are not inclined to interfere in the matter. The SLP is dismissed. The question of law, if any, shall be kept open,” the bench said.
Case Title : The Income Tax Officer & Ors. v. Man Mohan Agarwal HUF
Case Number : Petition(s) for Special Leave to Appeal (C) No(s). 4270/2026
CITATION : 2026 LLBiz SC 38
The Supreme Court has dismissed a Special Leave Petition filed by the Income Tax Department against a common Telangana High Court judgment setting aside reassessment notices issued against several taxpayers as time-barred. The plea challenged a common judgment of the Telangana High Court, which endorsed the Delhi High Court's view that mere generation or signing of a reassessment notice does not amount to issuance and that a notice is issued only when it is dispatched.
Case Title : DEPUTY COMMISSONER OF INCOME TAX CENTRAL CIRCLE 01 CHANDIGARH & ANR. VS FINDOC FINVEST PRIVATE LIMITED
Case Number : Diary No. 71435/2025
The Supreme Court on Monday issued notice on an appeal by the Income Tax Department against a Punjab and Haryana High Court judgment that held that an Assessing Officer abdicated his quasi-judicial function by repeatedly consulting superior officers before passing an assessment order. A bench of Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe issued notice on both the application seeking condonation of delay and the Special Leave Petition. The matter is listed next on March 16, 2026.
PIL In Supreme Court Challenges Income Tax Law Allowing Search Of Digital Devices, Cloud Data
Case Title : Vishwaprasad Alva v. Union of India
Case Number : W.P.(C) No. 114/2026
A public interest litigation has been filed before the Supreme Court challenging the constitutionality of provisions in the Income Tax Act, 2025 that empower tax authorities to conduct searches of “computer systems” and “virtual digital space”, including personal electronic devices, cloud servers, emails and private communications. The plea, filed under Article 32 of the Constitution by entrepreneur Vishwaprasad Alva, assails Section 247 of the Income Tax Act, 2025, as well as the corresponding provisions under Section 132 of the Income Tax Act, 1961.
Case Title : Arun Singh v. Union of India
Case Number : Diary No. 50293/2025
The Supreme Court on Wednesday dismissed a plea seeking directions to introduce safeguards so that property buyers are not unknowingly penalised for failing to deduct tax at source (TDS) while purchasing property worth more than Rs 50 lakhs. A bench of Justice Vikram Nath and Justice Sandeep Mehta heard the matter and dismissed the petition after brief submissions.
Case Title : Sirez Limited vs. Union of India & Ors.
Case Number : Special Leave to Appeal (C) No.4721/2026
The Supreme Court is to examine whether a delay in filing a return of income can be condoned under Section 119(2)(b) of the Income Tax Act, 1961. A Bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan issued notice in a Special Leave Petition filed by Sirez Limited challenging the judgment dated December 8, 2025, of the Delhi High Court.
Case Title : DEPUTY COMMISSIONER OF INCOME TAX 3 VS M/S RELIANCE INDUSTRIES LTD
Case Number : Special Leave to Appeal (C) No(s). 7819/2026
CITATION : 2026 LLBiz SC 92
The Supreme Court recently declined to entertain the Income Tax Department's Special Leave Petition against a Bombay High Court judgment that had quashed assessment orders passed in the names of Reliance Polyethylene Limited and Reliance Polypropylene Limited after they had ceased to exist following their merger with Reliance Industries Limited. A bench of Justices Pamidighantam Sri Narasimha and Alok Aradhe dismissed the petition after recording that, pursuant to the High Court's ruling, the department had already issued a fresh notice on July 17, 2025.
Case Title : Vishwaprasad Alva vs Union of India
Case Number : WP(C) No. 114 of 2026
CITATION : 2026 LLBiz SC 102
The Supreme Court on Monday declined to entertain a petition challenging the constitutional validity of the search and seizure powers over digital devices under Section 132 of the Income Tax Act, 1961, and its corresponding provision, Section 247 of the Income Tax Act, 2025, which is set to come into force from April 1, 2026. A bench comprising Chief Justice Surya Kant and Justice Joymalya Bagchi, however, permitted the petitioner to submit a representation to the Government of India seeking modifications or clarifications regarding the provision. The Court dismissed the writ petition as withdrawn.
Case Title : PR. COMMISSIONER OF INCOME TAX-3 VS DLF HOME DEVELOPERS LTD.
Case Number : DIARY NO 4477/2026
CITATION : 2026 LLBiz SC 108
The Supreme Court of India recently dismissed a Special Leave Petition filed by the revenue challenging a judgment of the Delhi High Court which had granted relief to DLF Home Developers Ltd. by deleting a disallowance of Rs 80.66 crore made under Section 14A of the Income-tax Act. The matter was heard by a bench comprising Chief Justice Surya Kant and Justices R. Mahadevan and Joymalya Bagchi. The Court held that the view taken by the Income Tax Appellate Tribunal and affirmed by the Delhi High Court warranted no interference.
Case Title : Assistant Commissioner of Income Tax vs Bharat Petroleum Corporation Ltd
Case Number : Diary No. 8091 OF 2026
CITATION : 2026 LLBiz SC 112
The Supreme Court on Monday refused to interfere with the Bombay High Court's order quashing income tax reassessment proceedings initiated against Bharat Petroleum Corporation Ltd. (BPCL) for AY 2013-14 in relation to Rs 37.10 crore dividend income received through a trust structure. A bench of Justices Pamidighantam Sri Narasimha and Alok Aradhe dismissed the Special Leave Petition, after being informed by the counsels that a previous matter on the same subject was dismissed by the supreme court.
HIGH COURTS
Allahabad HC
Allahabad High Court Stays Income Tax Revision, Cites No Definite Error In Reassessment Order
Case Title : Nitish Kumar Roy Versus Union Of India And Another
Case Number : WRIT TAX No. - 1036 of 2026
CITATION : 2026 LLBiz HC (ALL) 21
The Allahabad High Court has recently stayed proceedings pursuant to a show cause notice dated January 16, 2026 issued under Section 263 of the Income Tax Act, 1961 against an individual taxpayer, observing that the tax authority had not formed a definite opinion that the reassessment order was erroneous and prejudicial to the interest of the revenue. The order was passed by a bench of Justice Saumitra Dayal Singh and Justice Indrajeet Shukla.
Bombay HC
Bogus Purchases: Bombay High Court To Examine If ITAT Can Limit Disallowance To Profit Margin
Case Title : The Pr.Commissioner of Income Tax-17 Vs Chandrakant L. Nishar
Case Number : INCOME TAX APPEAL NO. 1879 OF 2019
CITATION : 2026 LLBiz HC(BOM) 88
The Bombay High Court has recently admitted an Income Tax Appeal filed by the Department and will examine the correct approach to disallowance in cases involving bogus purchases. A Division Bench of Justice M S Karnik and Justice S.M. Modak, by an order dated February 5, 2026, admitted the Revenue's appeal against Chandrakant L. Nishar.
Limitation For TDS Default Orders Runs Quarter-Wise, Not Annually: Bombay High Court
Case Title : The Commissioner of Income Tax (TDS), Pune Vs Vodafone Cellular Ltd., Pune
Case Number : INCOME TAX APPEAL NO.2438 OF 2018
CITATION : 2026 LLBiz HC(BOM) 116
The Bombay High Court has recently held that limitation for passing an order treating a person responsible for deducting tax at source as an “assessee in default” under Section 201 of the Income Tax Act must be computed quarter-wise based on the filing of each TDS statement, and not on an annual or cumulative basis. A Division Bench of Justice M.S. Karnik and Justice Gautam A. Ankhad on March 5, 2026 dismissed the Income Tax Department's appeal against Vodafone Cellular Ltd., Pune.
Case Title : The Chamber of Tax Consultants & Ors. v. The Commissioner of Income Tax (Exemptions) & Ors. [Writ Petition (L) No. 7587 of 2026]
Case Number : WRIT PETITION (L)NO.7587 OF 2026
CITATION : 2026 LLBiz HC(BOM) 154
The Bombay High Court has held that the absence of an explicit irrevocability clause in a trust deed cannot be a ground to reject the application of a charitable trust for registration or renewal under Section 12AB of the Income Tax Act, 1961. “The statute does not enact that the mere absence of an irrevocability clause makes a trust revocable. On the contrary, it implies that a trust is irrevocable (which is the normal principle in all transfers) unless it is expressly made revocable. Silence in the deed implies irrevocability, not revocability," a division bench of Justices B. P. Colabawalla and Firdosh P. Pooniwalla observed.
Calcutta HC
Case Title : Principal Commissioner of Income Tax v. M/s Express Tradelink Pvt. Ltd.
Case Number : ITAT 95 OF 2025
CITATION : 2026 LLBiz HC (CAL) 41
The Calcutta High Court on 4 February held that in share capital assessments, income tax additions cannot be sustained on mere suspicion, when the investors are identifiable, the taxpayers and share subscriptions are backed by audited records, and clear there are clear banking trails for transactions. A Division Bench of Justice Rajarshi Bharadwaj and Justice Uday Kumar dismissed an appeal filed by the Principal Commissioner of Income Tax, Kolkata, against Express Tradelink Pvt. Ltd. (taxpayer) for the Assessment Year 2009-10.
Change Of Opinion Not Enough To Reopen Assessment: Calcutta High Court
Case Title : Principal Commissioner of Income Tax-1, Kolkata v. Russel Credit Limited
Case Number : ITAT 153 OF 2025
CITATION : 2026 LLBiz HC (CAL) 57
The Calcutta High Court on 20 February held that revisional powers under Section 263 of the Income Tax Act, 1961 cannot be invoked merely because the Principal Commissioner holds a different opinion on the nature of income. A Division Bench of Justice Rajarshi Bharadwaj and Justice Uday Kumar, dismissed an appeal filed by the Principal Commissioner of Income Tax, Kolkata, and upheld the order of the Income Tax Appellate Tribunal setting aside revisionary proceedings against Russel Credit Limited for the Assessment Year 2018–19.
'Reimbursements' Fixed As Percentage Of Sales Are Contractual, Liable For TDS: Calcutta High Court
Case Title : Deys Medical Pvt. Ltd. v. Principal Commissioner of Income Tax
Case Number : ITAT 160 OF 2024
CITATION : 2026 LLBiz HC (CAL) 58
The Calcutta High Court has upheld the disallowance of expenses claimed by Deys Medical Private Limited (appellant) on account of alleged reimbursements paid to its group companies, holding that payments calculated as a percentage of sales constituted contractual consideration liable for tax deduction at source (TDS). The appeal arose from an order of the Income Tax Appellate Tribunal, Kolkata, which had partially affirmed the Assessing Officer's disallowance of over Rs. 3.35 crore under the Income Tax Act for failure to deduct at source on payments made towards advertisement, sales promotion, marketing, handling, storage and collection services.
Delhi HC
Case Title : International Buddhist Confederation v. ITO
Case Number : ITA 18/2026
CITATION : 2026 LLBiz HC (DEL) 117
The Delhi High Court has granted tax exemption to the International Buddhist Confederation, a Non-Governmental Organisation holding that tax authorities can't deny statutory benefits merely because of an inadvertent disclosure error made in the income tax return. A division bench of Justices Dinesh Mehta and Vinod Kumar also criticised the Revenue for taking advantage of the assessee's ignorance of his rights while passing the scrutiny assessment.
Delhi High Court Cuts TDS To 0.5% for UK Company Travelport, Sets Aside 1.6% Certificate
Case Title : Travelport International Operations Limited v. Deputy Commissioner Of Income-Tax Circle Int. Tax 3(1)(1), Delhi & Ors.
Case Number : W.P.(C) 7633/2025
CITATION : 2026 LLBiz HC (DEL) 118
The Delhi High Court has granted partial relief to UK-based travel technology company Travelport International Operations Limited by setting aside a tax withholding certificate that required deduction of tax at 1.6%. A division bench of Justices Dinesh Mehta and Vinod Kumar directed the tax authorities to issue a fresh certificate providing deduction of tax at a reduced rate of 0.5%.
Case Title : Branch Metrics Inc v. Deputy Commissioner Of Income Tax Circle International Tax 1 1 2 New Delhi
Case Number : W.P.(C) 17222/2025
CITATION : 2026 LLBiz HC (DEL) 129
The Delhi High Court has flagged an administrative issue in the processing of applications under Section 197 of the Income Tax Act, noting that a mismatch between the dates on orders and certificates issued for lower or nil tax deduction can create a misleading impression of delay. The court noted that while the certificate may be issued later, the order deciding the application often bears the date of filing of the application.
Wrong Attachment In Reassessment Email Does Not Invalidate Income Tax Notice: Delhi High Court
Case Title : Pawan Sachdeva v. Income-Tax Officer, Ward 19(3), Delhi & Anr.
Case Number : W.P.(C) 1328/2026
CITATION : 2026 LLBiz HC (DEL) 130
The Delhi High Court has held that an inadvertent attachment of another assessee's notice along with a reassessment email doesn't invalidate proceedings under Section 148 of the Income Tax Act, 1961, so long as the substance of the communication clearly indicates that the statutory notice was intended for the concerned assessee. A division bench of Justices Dinesh Mehta and Vinod Kumar thus dismissed the writ petition filed by an assessee challenging the continuation of reassessment proceedings for Assessment Year 2012–13 on the ground that the email sent by the Assessing Officer had erroneously attached a notice pertaining to a third party.
Case Title : MHJ Metaltechs Pvt Ltd v. Income Tax Officer, Ward 16(1), Delhi
Case Number : W.P.(C) 880/2026
CITATION : 2026 LLBiz HC(DEL) 131
The Delhi High Court has held that an Assessing Officer is not required to supply the entire material on record to an assessee at the stage of issuing a notice under Section 148A of the Income Tax Act ,1961 (re-assessment stage) observing that such a requirement would unnecessarily protract reassessment proceedings and enable assessees to manufacture defences.
A division bench of Justices Dinesh Mehta and Vinod Kumar observed, “If it is held that every material has to be supplied to the assessee along with the notice under Section 148A(1) or Section 148A(b) (as applicable from time to time), it will result in protraction of the proceeding and giving assessee unwarranted opportunity to defend the transactions, which he had withheld while filing the return of income by way of getting the relevant material or defence manufactured.”
Case Title : The Pr. Commissioner Of Income Tax -Central -1 v. Sperry Plast Ltd.
Case Number : ITA 90/2026
CITATION : 2026 LLBiz HC(DEL) 132
The Delhi High Court has recently held that mere repayment of a loan within a short span of time, even within two days, does not by itself establish that the transaction was a sham or a bogus accommodation entry for the purposes of Section 68 of the Income Tax Act, 1961.
A division bench of Justices Dinesh Mehta and Vinod Kumar observed, “Simply because the loan has been paid within two days, it cannot be said with certitude that the loan was not a genuine loan and was only a paper entry. According to us, the other argument that no interest was paid to the creditor is also mis-placed because if the short-term loan for two-three days is taken, for whatever reason because of family or business relation or friendship, a creditor may advance the amount with lesser or even without interest.”
Case Title : Hitik Malhan v. UoI
Case Number : W.P.(C) 1604/2026
CITATION : 2026 LLBiz HC(DEL) 133
The Delhi High Court has reiterated that its writ jurisdiction under Article 226 of the Constitution cannot be invoked merely because a taxpayer disputes the correctness of facts or the material relied upon by the Assessing Officer in reassessment proceedings under the Income Tax Act, 1961.
A division bench of Justices Dinesh Mehta and Vinod Kumar observed, “A challenge to notice or proceedings can be considered normally, in case where the notice and proceedings are without jurisdiction. Simply because the petitioner thinks that the proceedings are not correct on facts and the material available with the Assessing Officer does not tally with the correct facts, the High Court's jurisdiction under Article 226 cannot be invoked.”
Delhi High Court Quashes Transfer Pricing Order After TPO Failed To Share Agreements Relied Upon
Case Title : Lindstrom Services India Private Limited v. Deputy/Assistant Commissioner Of Income Tax, Transfer Pricing - 2(2)(2) New Delhi & Anr.
Case Number : W.P.(C) 1721/2026
CITATION : 2026 LLBiz HC(DEL) 139
The Delhi High Court has recently has held that a Transfer Pricing Officer (TPO) is bound to furnish copies of agreements relied upon for benchmarking before finalising a transfer pricing adjustment. A division bench of Justices Dinesh Mehta and Vinod Kumar observed, “It is the settled position of law that any authority is bound to provide copies of the relied upon documents.”
Case Title : Commissioner Of Income Tax (Tds)-1, New Delhi v. M/S Mahagun (India) Pvt. Ltd.
Case Number : ITA 259/2025
CITATION : 2026 LLBiz HC (DEL) 141
The Delhi High Court has dismissed three appeals filed by the Income Tax Department challenging orders of the Income Tax Appellate Tribunal (ITAT) that had granted relief to Mahagun developers in a long-running dispute over deduction of tax at source (TDS) on lease rent payments made to the NOIDA Authority.
A Division Bench of Justices Dinesh Mehta and Justice Vinod Kumar rejected the appeals after noting that the controversy was squarely covered by its earlier ruling in Rajesh Projects (India) Pvt. Ltd. v. Commissioner of Income-tax (2017), which held that while TDS under Section 194-I of the Income Tax Act is applicable on lease rent paid to Greater Noida Developmental Authority, the law would operate prospectively from the date of that judgment.
Case Title : GoDaddy.com LLC v. Assistant/Deputy Commissioner Of Income Tax Circle 1(3)(1), International Taxation Delhi
Case Number : W.P.(C) 15023/2025
CITATION : 2026 LLBiz HC (DEL) 144
The Delhi High Court has held that domain name registration fees received by GoDaddy is not chargeable to income tax in India, in terms of the India-USA Double Taxation Avoidance Agreement. A division bench of Justices Dinesh Mehta and Vinod Kumar also criticised the Income Tax Department for refusing to grant a nil withholding tax certificate under Section 197 of the Income Tax Act, 1961, despite binding judicial precedent.
Case Title : Pr. Commissioner Of Income Tax, Central-3, Delhi v. Jindal Saw Ltd.
C ase Number : ITA 689/2025
CITATION : 2026 LLBiz HC (DEL) 155
The Delhi High Court has upheld an order of the Income Tax Appellate Tribunal (ITAT) holding that excise duty refund received by Jindal SAW Ltd. under the Kutch district incentive scheme is a capital receipt and not taxable as income. While dismissing the Income Tax Department's appeal, the Division Bench of Justices Dinesh Mehta and Vinod Kumar agreed with ITAT's view that the refund was granted under the Incentive Scheme 2001 for Economic Development of Kutch District, notified by the Government of Gujarat in the aftermath of the devastating 2001 earthquake, issued by the Government of Gujarat in Novermber 2011 after the earthquake in the Kutch area.
Reassessment Must Be Based On AO's Independent 'Reason To Believe,' Not Borrowed: Delhi High Court
Case Title : PR Commissioner Of Income Tax - 4, New Delhi v. M/S NTPC Ltd
Case Number : ITA 113/202
CITATION : 2026 LLBiz HC (DEL) 157
The Delhi High Court has dismissed the Income Tax Department's appeals against NTPC Ltd., holding that reassessment proceedings cannot be initiated merely on the basis of an audit objection and that the statutory requirement of “reason to believe” must be from independent satisfaction of the Assessing Officer (AO). A Division Bench of Justices Dinesh Mehta and Vinod Kumar observed, “the provision expressly used the language 'reason to believe' and the same has been interpreted by Hon'ble the Supreme Court and this Court that 'reason to believe' must be of the AO himself and must be based on sound reasoning. The reason and satisfaction has to be that of the authority exercising jurisdiction and not borrowed.”
Case Title : Narayan Industries v. ACIT Circle 60(1) New Delhi
Case Number : ITA 489/2022
CITATION : 2026 LLBiz HC (DEL) 159
The Delhi High Court has held that while duty drawback receipts are not eligible for deduction under Section 80-IC of the Income Tax Act, the excise and customs duties paid by a taxpayer on raw materials are required to be deducted/subsumed from the duty drawback while recomputing income in the facts of the case. A Division Bench of Justices Dinesh Mehta and Vinod Kumar partly allowed the appeal filed by Narayan Industries against ITAT order denying its claim for deduction under Section 80-IC in respect of duty drawback income.
Case Title : Financial And Risk Organisation Limited v. The Income Tax Officer Circle Int. Tax 1(3)(1) New Delhi
Case Number : W.P.(C) 17641/2025
CITATION : 2026 LLBiz HC (DEL) 160
The Delhi High Court has strongly criticised the Income Tax Department for relying on a long-set-aside assessment order to deny withholding tax relief, holding that such an approach amounts to a revenue-driven exercise contrary to law and judicial discipline. A Division Bench of Justices Dinesh Mehta and Vinod Kumar set aside the order passed under Section 197 of the Income Tax Act, 1961, which had directed deduction of tax at 15% instead of issuing a nil withholding certificate to a a UK-based company providing subscription-based financial information and software products.
Case Title : Sapphire Foods India Ltd v. Assistant Commissioner Of Income Tax Acit (Osd) Delhi & Ors.
Case Number : W.P.(C) 6159/2023
CITATION : 2026 LLBiz HC (DEL) 161
The Delhi High Court on Monday held that a completed income tax scrutiny assessment can't be reopened merely on the basis of an audit objection when no fresh tangible material has come to the Assessing Officer's notice. A Division Bench of Justice V. Kameswar Rao and Justice Vinod Kumar observed, “reopening the assessment on the basis of the objections of the Audit Party, shall in the above facts, amount to reviewing the assessment already made, as the relevant material was available with the assessing officer during that assessment.”
Case Title : Pr Commissioner Of Income Tax 4 New Delhi v. HCL Infotech Pvt Ltd
Case Number : ITA 26/2026
CITATION : 2026 LLBiz HC (DEL) 165
The Delhi High Court has recently held that the question whether delay in processing TDS refund is attributable to the assessee/taxpayer, for the purpose of denying interest under Section 244A(2) of the Income Tax Act, can be decided only by the Principal Commissioner/Commissioner and not by the Assessing Officer (AO).
A Division Bench of Justices Dinesh Mehta and Vinod Kumar observed, “Looking at the language used in sub-section (2) of Section 244A of the Act of 1961, we are of the firm opinion that in case, the Assessing Officer is of the view that the delay in processing the request for refund has been caused for reasons attributable to the assessee, it is „Principal Chief Commissioner or Chief Commissioner‟ or „Principal Commissioner or Commissioner‟ who shall decide the question as to which period is to be excluded.”
Case Title : British Airways PLC v. The Assistant Commissioner Of Income Tax Circle (Int. Tax) 1(1)(2), New Delhi & Anr.
Case Number : W.P.(C) 18856/2025
CITATION : 2026 LLBiz HC (DEL) 178
The Delhi High Court has set aside an order of the Income Tax Department issuing a 0.1% TDS certificate to British Airways under Section 197 of the Income Tax Act, 1961. A Division Bench of Justices Dinesh Mehta and Vinod Kumar directed the authorities to issue a NIL TDS certificate, holding that income from airline operations is exempt under the India–UK Double Taxation Avoidance Agreement (DTAA).
Case Title : Refinitiv US LLC v. The Income Tax Officer Circle Int. Tax 1(3)(1) New Delhi
Case Number : W.P.(C) 17674/2025
CITATION : 2026 LLBiz HC (DEL) 180
The Delhi High Court has recently set aside a 15% tax withholding certificate issued to Refinitiv US LLC, a financial market data company under Section 197 of the Income Tax Act, 1961. A Division Bench of Justices Dinesh Mehta and Vinod Kumar directed the tax authorities to issue a NIL TDS certificate in respect of income earned from its Matching Solutions services, holding that such income is not taxable in India under the India–US Double Taxation Avoidance Agreement (DTAA).
Case Title : Nayati Healthcare And Research Ncr Private Limited v. Assessment Officer, Income Tax Department
Case Number : W.P.(C) 1554/2026
CITATION : 2026 LLBiz HC (DEL) 181
The Delhi High Court has recently set aside an ex-parte best judgment assessment assessing the Nayati Healthcare and Research NCR Private Limited's income at Rs. 232 crore, which was passed while the company was undergoing Corporate Insolvency Resolution Process (CIRP). A Division Bench of Justice Dinesh Mehta and Vinod Kumar allowed the writ petition filed by the assessee, observing that at the relevant time the company was under CIRP and neither the suspended management nor the Interim Resolution Professional (IRP) was in a position to effectively represent the assessee before the Assessing Officer.
Delhi High Court Treats 5.25% Withholding Certificate Issued To EY As Nil
Case Title : Ernst & Young LLP v. Assistant Commissioner Of Income Tax, Circle International Tax-1-2-2, New Delhi
Case Number : W.P.(C) 2266/2026
CITATION : 2026 LLBiz HC (DEL) 182
The Delhi High Court has recently treated a 5.25% withholding tax certificate issued to Ernst & Young LLP (EY) under Section 195 of the Income Tax Act, 1961, as a NIL-rate certificate, holding that the tax officer acted contrary to an earlier binding order of the Court for the same assessment year. A Division Bench of Justices Dinesh Mehta and Vinod Kumar disposed of the writ petition filed by EY challenging the order of the Assistant Commissioner of Income Tax which had directed withholding at 5.25%.
Income Tax | Delay in Filing Form 67 Not Ground to Deny Foreign Tax Credit: Delhi High Court
Case Title : Real Time Data Services Private Limited v. Principal Commissioner Of Income Tax, Delhi-7 & Anr.
Case Number : W.P.(C) 959/2024
CITATION : 2026 LLBiz HC (DEL) 184
The Delhi High Court has held that a mere delay in filing Form 67, the prescribed declaration required to claim credit in India for taxes already paid abroad as required under Rule 128 of the Income Tax Rules, 1962 cannot be used to deny an assessee the substantive benefit of Foreign Tax Credit (FTC). A Division Bench of Justices Dinesh Mehta and Vinod Kumar made the observation while allowing a petition filed by Real Time Data Services Private Limited against the Principal Commissioner of Income Tax, Delhi.
Case Title : PGS Geophysical AS v. Income Tax Department, International Tax Circle 2(2)(2) New Delhi & Anr.
Case Number : W.P.(C) 9678/2025
CITATION : 2026 LLBiz HC (DEL) 185
The Delhi High Court has quashed a 7% withholding tax certificate issued to Norwegian company PGS Geophysical under Section 197 of the Income Tax Act, holding that seismic survey and data acquisition services rendered for offshore oil exploration cannot be characterised as “fees for technical services” (FTS) or royalty. A Division Bench of Justices V. Kameswar Rao and Vinod Kumar allowed the writ petition filed by the Norwegian company, which had been engaged by ONGC for conducting seismic data acquisition and related services in connection with oil and gas exploration activities.
Delhi High Court Quashes 15% TDS Certificate On SaaS Under India–US DTAA, Orders 2% Certificate
Case Title : Beeline Com LLC v. Income Tax Officer Ward Int Tax 11 2 Delhi & Anr.
Case Number : W.P.(C) 1867/2026
CITATION : 2026 LLBiz HC (DEL) 194
The Delhi High Court has quashed a 15% tax deduction at source (TDS) certificate issued under Section 197 of the Income Tax Act, in respect of payments made for Software-as-a-Service (SaaS) to a US-based company providing a web-based Vendor Management System (VMS) to Indian clients, including Infosys Ltd. A Division Bench of Justices Dinesh Mehta and Vinod Kumar held that the company had made out a prima facie arguable case on non-taxability under the India–US Double Taxation Avoidance Agreement (DTAA).
Case Title : Commissioner Of Income Tax – Exemption v. Kush Innovative Foundation
Case Number : ITA 115/2026
CITATION : 2026 LLBiz HC (DEL) 199
The Delhi High Court has held that the Income Tax Appellate Tribunal (ITAT) cannot direct the grant of registration under Sections 12AB (which grants income tax exemption to charitable trusts) and 80G (which allows donors to claim tax deductions on donations) of the Income Tax Act, 1961 without a proper inquiry into the genuineness of the charitable activities of the applicant trust. A Division Bench of Justices Dinesh Mehta and Vinod Kumar thus set aside an ITAT order which had directed the Department to grant registration to an assessee-trust, observing that registration under Section 12AB(1)(b), following provisional approval under Section 12AB(1)(c), is not automatic and requires statutory scrutiny by the competent authority.
Case Title : Mitsui Engineering & Ship.C v. The Asst. Director Of Income Tax
Case Number : W.P.(C) 6708/2005
CITATION : 2026 LLBiz HC (DEL) 205
The Delhi High Court has allowed the writ petition filed by a Japan-based maritime engineering and logistics company, seeking additional interest on a long-pending income tax refund, in light of the Supreme Court's ruling in Sandvik Asia Ltd. v. Commissioner of Income Tax. A Division Bench of Justices Dinesh Mehta and Vinod Kumar set aside a 2005 order passed by the Director of Income Tax (International Taxation), which had rejected the petitioner's application under Section 154 of the Income Tax Act seeking additional interest under Section 244(1A) for Assessment Year 1988–89.
Case Title : Legal Initiative For Forest And Environment Trust (Life Trust) v. PCIT Central 2 Delhi And Anr
Case Number : W.P.(C) 2342/2026
CITATION : 2026 LLBiz HC (DEL) 218
The Delhi High Court has reprimanded the Income Tax Appellate Tribunal (ITAT) for adjourning an appeal sine die after the matter had already been heard and reserved for judgment. For context, although Petitioner's appeal before the ITAT had been heard at length and reserved for orders on September 3, 2025, the Tribunal subsequently listed the matter again and, on January 19, 2026, adjourned it sine die.
Case Title : Lindstrom Services India Private Limited v. National Faceless Assessment Centre New Delhi & Ors.
Case Number : W.P.(C) 2723/2026
CITATION : 2026 LLBiz HC (DEL) 223
The Delhi High Court has recently quashed a draft assessment order passed by the Faceless Assessing Officer (FAO) against Lindstrom Services India, after noting that it was issued without knowledge of the Court's order quashing transfer pricing, due to delay in uploading the High Court direction on its website. The division bench of Justices Dinesh Mehta and Vinod Kumar clarified that while the FAO could not be faulted personally, an assessment order passed in ignorance of a subsisting High Court order cannot be allowed to stand.
Delhi High Court Directs 2% Withholding Tax Certificate For US Software Firm DocuSign
Case Title : DocuSign Inc v. The Income Tax Officer, Ward Int. Tax 1(2)(2), Civic Centre New Delhi
Case Number : W.P.(C) 1334/2026
CITATION : 2026 LLBiz HC (DEL) 225
The Delhi High Court has directed the Income Tax Department to issue a withholding tax certificate at the rate of 2% in favour of a US-based software company, after finding that the transactions prima-facie look to be not exigible to tax. A division bench of Justices Dinesh Mehta and Vinod Kumar passed the order while hearing DocuSign's writ petition challenging a certificate issued under Section 197 of the Income Tax Act, 1961.
Case Title : Gaurav Dalmia v. Deputy Director Of Income Tax Investigation Unit 2 (3) Delhi & Ors.
Case Number : W.P.(C) 8352/2025
CITATION : 2026 LLBiz HC (DEL) 226
The Delhi High Court has held that failure of tax authorities to obtain information about an assessee's assets in foreign jurisdictions cannot be used to keep a Look Out Circular (LOC) alive indefinitely, particularly when income tax proceedings have already concluded and no demand is outstanding against the assessee. A Division Bench of Justices Dinesh Mehta and Vinod Kumar thus allowed writ petitions filed by the assessees and observed, “If for one reason or the other, the respondents are not in a position to gather or elicit information from the foreign countries, the petitioners' rights cannot be kept suspended for an indefinite period. We are, therefore, of the view that the respondents' action of continuing with the lookout circular is violative of petitioners' fundamental rights.”
Case Title : Workday Limited v. Deputy Commissioner Of Income Tax Circle Int. Tax 3(1)(1), New Delhi
Case Number : W.P.(C) 731/2026
CITATION : 2026 LLBiz HC (DEL) 231
The Delhi High Court has held that while issuing a certificate for lower deduction of tax at source under Section 197 of the Income Tax Act, 1961, the competent authority is required to record a prima facie view on the taxability of the receipts, and that such certificates cannot be issued mechanically or without reasons. A division bench of Justices Dinesh Mehta and Vinod Kumar made the observation while disposing of a writ petition filed by Ireland-based Workday Limited, which had challenged a withholding certificate directing deduction of tax at the rate of 10% on payments received from India.
Case Title : BKR Capital Pvt. Ltd v. Income Tax Officer, Ward 4.1., Delhi
Case Number : W.P.(C) 19738/2025
CITATION : 2026 LLBiz HC (DEL) 255
The Delhi High Court has held that a reassessment notice issued under Section 148 of the Income Tax Act cannot be treated as time-barred when the delay occurred due to adjournments sought by the taxpayer during proceedings under Section 148A. A Division Bench of Justices Dinesh Mehta and Vinod Kumar dismissed writ petitions filed by two private companies challenging notices issued for Assessment Year (AY) 2017–18 on the ground that they were issued after the limitation period had expired.
Delhi High Court Sets Aside Rejection Of MakeMyTrip's NIL TDS Certificate, Calls Order Non-Speaking
Case Title : MakeMyTrip (India) Pvt Ltd v. Assistant Commissioner Of Income Tax, Circle-75(1), Delhi & Anr.
Case Number : W.P.(C) 11956/2025
CITATION : 2026 LLBiz HC (DEL) 263
The Delhi High Court has recently set aside an order of the Income Tax Department rejecting online travel company MakeMyTrip's application for a NIL or lower withholding tax certificate for FY 2025-26 (AY 2026-27) under Section 197 of the Income Tax Act. A division bench of Justices V. Kameswar Rao and Vinod Kumar observed that the impugned order was a non-speaking one and failed to provide reasons for the rejection. It observed, “...in the past, withholding certificates were issued at rates between 0.10% to 4% and the rejection of application has the effect of deducting normal rate of tax at source, which is clearly untenable, particularly when no reasons have been given in the impugned order for rejecting the application for NIL withholding certificate”.
Income Tax Assessment Order Against Amalgamated Boeing Entity Is Void: Delhi High Court
Case Title : Principal Commissioner Of Income Tax-1 v. Boeing India Pvt. Ltd.
Case Number : ITA 586/2025
CITATION : 2026 LLBiz HC (DEL) 265
The Delhi High Court has reiterated that an income tax assessment order passed in the name of a company that had ceased to exist following amalgamation is void ab initio and cannot be sustained in law. A division bench of Justices V. Kameswar Rao and Vinod Kumar thus dismissed an appeal filed by the Income Tax Department against Boeing India.
Case Title : Oravel Stays Ltd v. Commissioner Of Income-Tax (Tds)-2, Delhi & Ors.
Case Number : W.P.(C) 2932/2026
CITATION : 2026 LLBiz HC (DEL) 266
The Delhi High Court has quashed an order directing Oravel Stays Limited, the parent company of OYO, to deposit 20% of the outstanding tax demand as a condition for the grant of a stay during the pendency of its appeal. A division bench of Justices Dinesh Mehta and Vinod Kumar set aside the order passed by the Commissioner of Income Tax which had disposed of the company's stay application by directing payment of 20% of the total demand while keeping the remaining demand stayed.
Case Title : Huawei Telecommunications (India) Company Pvt. Ltd. v. Assistant Commissioner Of Income Tax, Central Circle-2, Delhi & Anr
Case Number : W.P.(C) 15970/2023
CITATION : 2026 LLBiz HC (DEL) 316
The Delhi High Court has granted partial relief to Huawei Telecommunications (India) in a batch of petitions challenging special audit directions and reassessment proceedings initiated by the Income Tax Department. A Division Bench of Justices V. Kameswar Rao and Vinod Kumar partly allowed the petitions, setting aside the special audit directions and reassessment notices for Assessment Year (AY) 2013-14, while sustaining the proceedings for AY 2015-16.
Case Title : Delhi Sports And Entertainment Private Limited v. Deputy Commissioner Of Income Tax & Ors.
Case Number : W.P.(C) 3152/2026
CITATION : 2026 LLBiz HC (DEL) 317
The Delhi High Court has quashed reassessment proceedings against a Delhi-based sports events company, holding that the notice issued on July 30, 2022 was time-barred and that reopening the case on issues already scrutinized amounted to a mere change of opinion, rendering the entire exercise invalid. A Division Bench of Justices Dinesh Mehta and Vinod Kumar allowed the writ petition filed by the company, setting aside the reassessment notice, subsequent orders, and the ex-parte assessment order raising a demand of over Rs. 96 crore.
Gujarat HC
Case Title : Solvay Specialities India Private Limited vs. Assistant Commissioner of Income Tax
Case Number : R/Special Civil Application No.7905 of 2024
CITATION : 2026 LLBiz HC (GUJ) 13
The Gujarat High Court has recently set aside a tax deduction at source order against Solvay Specialities India, holding that the Income Tax Department failed to apply the mandatory “make available” test under the India–Singapore tax treaty. Under this test, tax authorities are required to first determine whether the foreign service provider actually passed on any technical knowledge, skill, or know-how in a way that allows the Indian company to use it independently in the future.
Ten-Year Block Under Section 153A Includes Search Year: Gujarat High Court
Case Title : Bankim Chandramanishanker Joshi vs. Deputy Commissioner of Income Tax
Case Number : R/Special Civil Application No. 1254 of 2026
CITATION : 2026 LLBiz HC (GUJ) 22
The Gujarat High Court on 23 February held that tax authorities must include the search year when computing the ten-year block for reopening assessments under Section 153A of the Income Tax Act, 1961. A Bench comprising Justice A.S. Supehia and Justice Pranav Trivedi quashed a notice issued in 2025 for Assessment Year 2014-2015, as it fell outside the ten-year period, with the tenth year being Assessment Year 2015-16.
Case Title : Gopal Bhachabhai Jatiya vs. ITO Ward-1, Gandhidham
Case Number : R/Tax Appeal No. 15184 of 2024
CITATION : 2026 LLBiz HC (GUJ) 25
The Gujarat High Court has recently quashed reassessment proceedings initiated under Section 148A of the Income Tax Act against an individual taxpayer after noting that the Assessing Officer failed to consider that two sale deeds had been cancelled on account of fraud and that the sale consideration had been reversed. A bench of Justice A.S. Supehia and Justice Pranav Trivedi recorded that the sale deeds dated August 28 and 29, 2018, were subsequently cancelled by a competent authority because they had been executed by fraudulent persons.
DTVSV Scheme 2024 Inapplicable To Reassessments Arising From Search Proceedings: Gujarat High Court
Case Title : Radha Madhav Eco-Industrial Park v. Principal Commissioner of Income Tax & Anr.
Case Number : R/SPECIAL CIVIL APPLICATION NO. 3627 of 2025
CITATION : 2026 LLBiz HC(GUJ) 29
The Gujarat High Court on 18 February held that taxpayers whose reassessment proceedings arise from incriminating material discovered during search operations under Sections 132 or 132A of the Income Tax Act are not eligible to avail the benefit of the Direct Tax Vivad Se Vishwas (DTVSV) Scheme, 2024. A Division Bench of Justice A.S. Supehia and Justice Pranav Trivedi dismissed a batch of writ petitions led by Radha Madhav Eco-Industrial Park, which challenged the rejection of their applications under the scheme.
Case Title : Gulbrandsen Pvt. Ltd. v. DY. Commissioner of Income Tax Circle
Case Number : R/SPECIAL CIVIL APPLICATION NO. 15851 of 2025
CITATION : 2026 LLBiz HC(GUJ) 31
The Gujarat High Court on 24 February ruled that the Revenue cannot initiate reassessment proceedings under Section 148 of the Income Tax Act based on the same material that was already scrutinised in the original proceedings, which later lapsed due to the Assessing Officer's failure to meet the statutory deadlines. The Division Bench of Justice A.S. Supehia and Justice Pranav Trivedi held that reopening an assessment in such circumstances is an impermissible attempt to “camouflage” administrative remissness and indirectly extend the period of limitation for finalising an assessment.
Case Title : Jay Pareshbhai Soni v. Income Tax Officer Ward & Ors.
Case Number : R/SPECIAL CIVIL APPLICATION NO. 2902 of 2026
CITATION : 2026 LLBiz HC(GUJ) 33
The Gujarat High Court has set aside an order transferring an assessee's income-tax reassessment case from Ahmedabad to Rajkot after finding that the transfer was made without granting the taxpayer an opportunity of hearing as required under the Income Tax Act. The division bench of Justice A. S. Supehia and Justice Pranav Trivedi held that in the present case the transfer of jurisdiction under Section 127(2) of the Income Tax Act could not be sustained since it had been effected without affording the petitioner a reasonable opportunity of hearing, which is mandatory under the provision.
CIT Cannot Reject Delay Condonation Plea On Grounds Beyond Scope of Application: Gujarat High Court
Case Title : Shri Jain Dehrasar Upasraya Ane Sadharan v. Commissioner of Income Tax (Exemption), Ahmedabad
Case Number : R/SPECIAL CIVIL APPLICATION NO.9992 of 2024
CITATION : 2026 LLBiz HC(GUJ) 34
The Gujarat High Court on 9 March held that while deciding an application for condonation of delay under Section 119(2)(b) of the Income Tax Act, the Authority cannot examine issues beyond the scope of the delay condonation request. A Division Bench of Justice A. S. Supehia and Justice Pranav Trivedi held that the Commissioner of Income Tax (Exemption) wrongly rejected Shri Jain Dehrasar Upasraya Ane Sadharan's delay condonation plea for filing Form 10B by questioning its registration status instead of examining the explanation for the delay.
Case Title : Ambalal Sarabhai Enterprises Limited v. The Deputy Commissioner of Income Tax, Circle 1, Vadodara
Case Number : R/TAX APPEAL NO.640 of 2022
CITATION : 2026 LLBiz HC(GUJ) 36
The Gujarat High Court has held that money received from transferring a self-generated trademark before 2002 cannot be taxed as capital gains, as the law allowing such taxation came into force only later. The Court noted that Section 55(2) of the Income Tax Act was amended with effect from April 1, 2002, to allow taxation of transfers of trademarks by treating their cost of acquisition as nil, and the amendment cannot apply to earlier transactions.
Search Year Must Be Included While Computing 10-Year Block For Reassessment: Gujarat High Court
Case Title : Dilipbhai Prabhudas Patel v. Deputy Commissioner of Income Tax
Case Number : R/SPECIAL CIVIL APPLICATION NO. 2403 of 2026
CITATION : 2026 LLBiz HC(GUJ) 38
The Gujarat High Court on 9 March, held that while computing the extended ten-year block period for reassessment in search cases, the assessment year relevant to the previous year in which the search is conducted (search assessment year) must be included in the computation. The Division Bench comprising Justice A. S. Supehia and Justice Pranav Trivedi quashed the notice issued to Dilipbhai Prabhudas Patel (petitioner) under Section 148 of the Income Tax Act. The Bench held: "The statutory language necessarily results in inclusion of the search assessment year within the ten-year reckoning. Any interpretation that applies the six-year exclusion model, if made applicable to the ten-year block, would defeat the legislative scheme and render material words redundant. Accordingly, while computing the extended ten-year period under Explanation 1 to Section 153A read with Section 153C of the Act, the assessment year relevant to the previous year of search is to be included in the reckoning."
Case Title : Herald Global Ventures Pvt. Ltd v. The Chief Commissioner of Income Tax
Case Number : R/SPECIAL CIVIL APPLICATION NO. 11722 of 2024
CITATION : 2026 LLBiz HC(GUJ) 43
The Gujarat High Court on 16 March, held that a bona fide delay of 53 days in filing Form 10-IC cannot deprive an eligible taxpayer of concessional tax benefits. The expression “genuine hardship” under the Income Tax Act must be given a liberal, justice-oriented interpretation. Form 10-IC is a declaration filed by a company to opt for the concessional corporate tax rate under Section 115BAA of the Income Tax Act.
A Bench comprising Justice A.S. Supehia and Justice Pranav Trivedi allowed Herald Global Ventures Private Limited to avail benefits under Section 115BAA of the Income Tax Act. The judges held: "……if the delay in question is not condoned, the petitioner will have to pay substantial tax calculated as per 'normal rate of tax' despite the fact that the petitioner is otherwise eligible for claiming benefit under section 115BAA of the Act i.e. 'tax rate being 22%'. This will result into 'financial hardship' to the petitioner which is a 'genuine hardship'. Thus, by condoning delay, the genuine hardship caused to the petitioner could have been avoided."
Case Title : RAR Properties v. Principal Commissioner of Income Tax
Case Number : R/SPECIAL CIVIL APPLICATION NO. 2148 of 2026
CITATION : 2026 LLBiz HC(GUJ) 44
The Gujarat High Court has held that a taxpayer's delay in filing its income tax return due to a bona fide misunderstanding of audit requirements under Section 44AB of the Income Tax Act, resulting in denial of a tax deduction under Section 80-IAB for Special Economic Zone developers, constitutes “genuine hardship” warranting condonation. The case arose from the petitioner firm's failure to file its return of income for Assessment Year 2023–24 within the prescribed due date of 31 July 2023. The delay of 87 days was attributed to incorrect professional advice that the firm was required to get its accounts audited under Section 44AB of the Income Tax Act.
Case Title : Purvibhavin Shah v. The Income Tax Officer
Case Number : R/SPECIAL CIVIL APPLICATION NO. 3845 of 2026
CITATION : 2026 LLBiz HC(GUJ) 48
The Gujarat High Court has recently held that while computing the extended ten-year period for reopening income tax assessments following a search, the assessment year in which the search was conducted must be included in the reckoning. The bench stated that "..... the assessment year relevant to the previous year of search becomes the reference year and the ten-year period is counted from the end of that assessment year. This necessarily includes the search assessment year within the ten-year framework and resultantly, the search year becomes the first year in the reckoning of the ten-year block."
Jammu & Kashmir And Ladakh HC
J&K&L High Court Upholds Income Tax Addition After Taxpayer Gave Inflated Stock Statement To Bank
Case Title : Ajay Food Products vs Income Tax Officer and others, 2026
Case Number : ITA No. 16/2007
CITATION : 2026 LLBiz HC (JAM) 8
The Jammu & Kashmir and Ladakh High Court on Wednesday upheld an addition to taxable income made on the basis of a stock statement furnished by a taxpayer to a bank while availing a cash credit facility, holding that the tax authorities were justified in relying on the declaration where discrepancies with the books of account remained unexplained. A Division Bench of Chief Justice Arun Palli and Justice Rajnesh Oswal dismissed an appeal filed by Ajay Food Products challenging an addition made by the Income Tax Department on the basis of stock statements submitted to the bank.
Case Title : Vidya Sagar Sharma vs Union of India, 2026
Case Number : WP(C) No. 536/2025
CITATION : 2026 LLBiz HC (JAM) 10
The Jammu & Kashmir and Ladakh High Court has held that under the Direct Tax Vivad Se Vishwas Act, 2020, failure to comply with the conditions of the scheme results in automatic revival of all proceedings withdrawn earlier, irrespective of whether they were initiated by the assessee or the Income Tax Department. A Division Bench of Chief Justice Arun Palli and Justice Rajnesh Oswal ruled that Section 4(6) of the act applies to “all proceedings and claims” without distinction, and therefore revival operates by law even in respect of revision petitions filed by the assessee.
Karnataka HC
Case Title : Bhoruka Steel and Services Ltd. v. Assistant Commissioner of Income Tax
Case Number : WRIT PETITION NO. 17592 OF 2022
CITATION : 2026 LLBiz HC (KAR) 13
The Karnataka High Court has recently held that reassessment proceedings initiated after the expiry of the statutorily surviving period of limitation under the Income Tax Act are invalid. This remains so even where the revenue seeks to sustain the reassessment notice on the basis of the Supreme Court's directions in Union of India v. Ashish Agarwal.
Tax Authority Cannot Deny Interest Waiver Through A Cryptic Order: Karnataka High Court
Case Title : M/s Kanhaiyalal Dudheria v. The Chief Commissioner
Case Number : WRIT PETITION NO. 104240 OF 2025
CITATION : 2026 LLBiz HC (KAR) 17
The Karnataka High Court recently held that a tax authority cannot deny a taxpayer's request for interest waiver through a cryptic order. It must pass a reasoned, speaking order after objectively examining whether the income could have been anticipated at the relevant time. A Bench of Justice K.S. Hemalekha, partly allowed a writ petition filed by Kanhaiyalal Dudheria (petitioner) and partially set aside an order of the Chief Commissioner of Income Tax, that allowed waiver of the second and third advance tax instalments.
Case Title : United Spirits Limited v. Deputy Commissioner of Income Tax
Case Number : WRIT PETITION No.18439 OF 2024
CITATION : 2026 LLBiz HC (KAR) 45
Rejecting the income tax department's attempt to treat a Tribunal remand as a fresh transfer pricing reference to extend limitation, the Karnataka High Court has held that no order can be passed once the statutory time limit expires. A single-judge bench of Justice Nagaprasanna emphasised that there is a “world of difference” between a reference made by the Assessing Officer to the Transfer Pricing Officer under Section 92CA(1) and a remand of the matter by the Tribunal, rejecting the Revenue's attempt to treat both as triggering a fresh limitation period.
Kerala HC
BSNL VRS Retirees Absorbed From DoT Entitled To Leave Encashment Tax Exemption: Kerala High Court
Case Title : Sanchar Nigam Pensioners Welfare Association v. Union of India
Case Number : WP(C) NO. 16360 OF 2023
CITATION : 2026 LLBiz HC (KER) 35
The Kerala High Court has held that retired BSNL employees who were originally absorbed from the Department of Telecommunications (DoT) are entitled to full income-tax exemption on leave encashment under the Income Tax Act, 1961. The writ petition was filed by the Sanchar Nigam Pensioners' Welfare Association and two retired officers of Bharat Sanchar Nigam Limited, who had opted for the BSNL voluntary Retirement Scheme, 2019.
Taxpayer Cannot Escape Prosecution By Filing Revised Returns Post-Search: Kerala High Court
Case Title : Shammem Majeed v. State of Kerala
Case Number : CRL.MC NO. 8014 OF 2019
CITATION : 2026 LLBiz HC (KER) 41
The Kerala High Court on 20 February held that filing revised income tax returns after a search and seizure operation does not absolve a taxpayer from criminal prosecution for wilful tax evasion, and that such revised returns cannot be used as a shield against offences punishable under the Income Tax Act, 1961. Justice G. Girish, dismissed a batch of petitions filed by a medical practitioner challenging prosecutions pending before the Additional Chief Judicial Magistrate (Economic Offences), Ernakulam.
Case Title : Dr. P.H. Abdul Majeed v. State of Kerala
Case Number : CRL.MC NO. 7884 OF 2019
CITATION : 2026 LLBiz HC (KER) 43
The Kerala High Court has reiterated that criminal prosecutions for alleged tax evasion under the Income Tax Act do not automatically fail merely because penalty proceedings were set aside on technical grounds, and that such prosecutions can validly continue where allegations disclose wilful and deliberate concealment of income. The ruling was delivered by Justice G. Girish while dismissing a batch of criminal miscellaneous petitions filed by Dr. P.H. Abdul Majeed, who had sought the quashing of multiple criminal complaints initiated by the Income Tax Department for offences under Sections 276C(1) and 277 of the Income Tax Act.
Case Title : The Principal Commissioner of Income Tax v. Kalyan Jewellers India Ltd.
Case Number : ITA NO. 71 OF 2025
CITATION : 2026 LLBiz HC (KER) 58
The Kerala High Court on 11 March, held that unrealised gains arising from mark-to-market valuation of forward contracts are not taxable as income unless actually realised. The Division Bench comprising Justice Devan Ramachandran and Justice Basant Balaji dismissed the appeal filed by the Principal Commissioner of Income Tax against Kalyan Jewellers India Ltd. The judges held: “It is doubtless that, in a 'mark-to-market' forward commodities contract, the gains and losses fluctuate until the instrument matures on the period of expiry. In one year it is likely that there would be losses, which would perhaps transmute to be profits in the next year; and it continues in that cycle until the maturity happens.”
Madras HC
Transfer Pricing Reference During Extended Reassessment Period Invalid: Madras High Court
Case Title : Eaton Power Quality Private Limited v. The Deputy Commissioner of Income Tax
Case Number : W.P.No.15393 of 2022
CITATION : 2026 LLBiz HC (MAD) 38
The Madras High Court held that a reference to the Transfer Pricing Officer (TPO) made during the extended period available for completion of reassessment is invalid, rendering the proceedings time-barred. Justice C. Saravanan delivered the judgment while allowing a writ petition filed by Eaton Power Quality Private Limited which challenged the order passed by the TPO under Section 92CA(3) of the Income Tax Act by which the arm's length price of corporate service fees was determined at nil and a downward adjustment was proposed.
Case Title : C Joseph Vijay v. The Deputy Commissioner of Income Tax and others
Case Number : WP No. 21006 of 2022
The Madras High Court on Friday dismissed a plea by actor-turned-politician Vijay challenging a Rs 1.5 crore penalty imposed on him by the Income Tax Department in connection with alleged undisclosed income of Rs 15 crore for the financial year 2015–16. The judgment was pronounced by a single judge, Justice Senthilkumar Ramamoorthy, after reserving the same on January 23, 2026.
Case Title : Motilal Jain Mahaveer Jain v. Income Tax Officer
Case Number : W.P.No.23246 of 2023
CITATION : 2026 LLBiz HC (MAD) 61
The Madras High Court has clarified that a non-resident individual falls within the amended definition of an “eligible assessee” under the Income Tax Act, and therefore reassessment proceedings routed through the Dispute Resolution Panel cannot be challenged on that ground. The court dismissed a writ petition filed by individual taxpayers Motilal Jain and Mahaveer Jain and upheld a reassessment order issued under the Income Tax Act following directions of the Dispute Resolution Panel.
Case Title : Verizon Data Services India Private Limited v. Deputy Commissioner of Income Tax
Case Number : W.P.No18377 of 2024
CITATION : 2026 LLBiz HC (MAD) 68
The Madras High Court has recently quashed penalty proceedings against Verizon Data Services India Pvt Ltd, holding that a transfer pricing adjustment based on estimation of arm's length price cannot by itself constitute “misreporting of income” under Section 270A of the Income Tax Act. A single-bench of Justice C. Saravanan, while quashing the penalty order and rejection of its immunity application against Verizon observed, "The entire basis for initiation of penalty proceedings is the transfer pricing adjustment proposed in the draft assessment order. Such adjustment, by its very nature, involves estimation and determination of arm's length price and cannot, in law, be equated with either concealment or misrepresentation so as to attract the Clause (a) to Sub Section (9) to Section 270A."
No Penalty For Erroneous Claim Based On Bona Fide Interpretation Of Tax Treaty: Madras High Court
Case Title : Commissioner Of Income Tax Chennai v. Indian Overseas Bank
Case Number : TCA Nos. 64 and 65 of 2014
CITATION : 2026 LLBiz HC (MAD) 71
The Madras High Court on 5 February held that an erroneous claim of double taxation relief by itself cannot lead to a penalty under Section 271(1)(c) of the Income Tax Act, 1961 when the taxpayer has fully disclosed the relevant income and the claim arises from a bona fide interpretation of law. A Division Bench of Dr. Justice Anita Sumanth and Justice Mummineini Sudheer Kumar heard appeals filed by the Commissioner of Income Tax against Indian Overseas Bank challenging an order of the Income Tax Appellate Tribunal (Tribunal), which had deleted the penalty imposed on the bank for the assessment years 2006–07 and 2007–08.
Penalty Order Is In Limitation If Issued Within Six Months Of Appellate Order: Madras High Court
Case Title : Chandrasekaran Joseph Vijay v. The Deputy Commissioner of Income Tax
Case Number : WP No. 21006 of 2022
CITATION : 2026 LLBiz HC (MAD) 70
The Madras High Court on 6 February held that when penalty proceedings arise from assessment orders and the assessment is challenged on appeal, the limitation period for issuing a penalty can be computed from the appellate order. A penalty issued within the prescribed period after the appellate decision is therefore not time-barred. Justice Senthilkumar Ramamoorthy upheld a penalty imposed on actor Joseph Vijay under the Income Tax Act, 1961, observing that the penalty order dated 30 June 2022 was issued within the statutory period under Section 275(1)(a). The Court noted that appellate proceedings effectively reset the clock for penalty orders arising from assessments.
Vehicle Possession And Document Transfer Concludes A Sale For Capital Gains Tax: Madras High Court
Case Title : Dr. Arvind Kumar R Shaw v. Union of India
Case Number : W.P.No.14256 of 2024
CITATION : 2026 LLBiz HC (MAD) 73
The Madras High Court has held that delivery of a vehicle along with its original documents may constitute a completed sale for income-tax purposes, even if the registration certificate is not formally transferred in the buyer's name. A Bench comprising Justice C. Saravanan dismissed the writ petition filed by Dr. Arvind Kumar R. Shaw (the petitioner), upholding the assessment order passed by the Income Tax Department treating the sale of his Rolls‑Royce as a short-term capital gains transaction for the assessment year 2018–19.
Madras High Court Dismisses Taxpayer Appeal, Says Books Were Rejected Before DVO Reference
Case Title : M. Ravindran v. The Income Tax Officer
Case Number : T.C.A.No.201 of 2013
CITATION : 2026 LLBiz HC (MAD) 78
The Madras High Court has held that the Assessing Officer was justified in referring the matter to the District Valuation Officer after examining the books of accounts and finding inconsistencies in them, and that the taxpayer could not rely on the Supreme Court's ruling in Sargam Cinema to argue that the reference to the Valuation Officer was invalid. The Division Bench of Justice G. Jayachandran and Justice Shamim Ahmed dismissed the tax appeal filed by taxpayer M. Ravindran and affirmed the findings recorded by the tax authorities as well as the tribunal.
Case Title : M/s. Wheels India Limited v. The Assistant Commissioner of Income Tax
Case Number : T.C.A.No.104 of 2015
CITATION : 2026 LLBiz HC (MAD) 87
The Madras High Court on 2 March held that a taxpayer is entitled to claim the balance 50% of additional depreciation in the subsequent assessment year where new plant and machinery are put to use for less than 180 days in the year of acquisition. A Bench of Justice G. Jayachandran and Justice Shamim Ahmed allowed an appeal filed by Wheels India Limited against an order of the Income Tax Appellate Tribunal for the assessment year 2007–08, which had upheld the partial disallowance of the company's claim for additional depreciation.
Orissa HC
Orissa High Court Grants Interim Relief to Taxpayer Against Non-Faceless IT Reassessment
Case Title : Bibekananda Parida v. Central Board of Direct Taxes (CBDT) and Others
Case Number : WP(C) No.22306 of 2025
CITATION : 2026 LLBiz HC(ORI) 9
The Orissa High Court on 2 February restrained the Income Tax Department from proceeding further on a reassessment notice issued to a Bhubaneswar-based taxpayer, after finding that the notice was not issued in accordance with the mandatory faceless procedure prescribed under the Income Tax Act, 1961. The Division Bench of Chief Justice Harish Tandon and Justice M.S. Raman was hearing a writ petition filed by Bibekananda Parida, challenging an order passed under Section 148A of the Income Tax Act along with a reassessment notice issued under Section 148.
Orissa High Court Grants Fresh Hearing To Taxpayer With Neurological Illness, Quashes Ex Parte Order
Case Title : Sri Susil Nath v. Income Tax Officer, National Faceless Centre, New Delhi & Anr.
Case Number : W.P.(C) No.154 of 2026
CITATION : 2026 LLBiz HC (ORI) 10
The Orissa High Court on 2 February set aside an ex parte assessment order against Sri Susil Nath, the taxpayer, as he could not participate due to neurological illness. A Division Bench of Chief Justice Harish Tandon and Justice Murahari Sri Raman noted: “As it appears from the record that the invoices along with vehicle particulars issued by the Government Authority could not be placed before the said Authority in view of the circumstances beyond the control of the petitioner.”
Extraordinary Writ Jurisdiction Cannot Be Invoked In Factual Disputes: Orissa High Court
Case Title : Saroj Kumar Sahoo v. National Faceless Assessment Centre & Anr.
Case Number : W.P.(C) No. 30861 of 2025
CITATION : 2026 LLBiz HC(ORI) 11
The Orissa High Court on 18 February, held that questions involving disputed facts, including the existence and relevance of incriminating material, cannot be examined in writ proceedings under Articles 226 and 227 of the Constitution. A Division Bench of Chief Justice Harish Tandon and Justice Murahari Sri Raman, while dismissing a writ petition filed by Saroj Kumar Sahoo, emphasised that extraordinary writ jurisdiction is not available where an effective alternative remedy exists under the Income Tax Act.
Punjab & Haryana HC
Case Title : Sanjeet Singh and others v. Principal Director of Income Tax (Investigation), Chandigarh and others
Case Number : CWP-31147-2025 (O&M)
CITATION : 2026 LLBiz HC (PNH) 10
The Punjab and Haryana High Court on 18 February, directed the Income Tax Department to immediately release jewellery seized from the Sanjeet Singh and other petitioners, holding that the department cannot demand a higher bank guarantee due to an increase in gold prices when the delay in release was solely attributable to administrative lapses of the authorities. A Division Bench of Justice Deepak Sibal and Justice Lapita Banerji allowed a writ petition which sought the release of jewellery seized during a search operation at the residential premises and bank lockers of Singh.
Rajasthan HC
Assessment Order Against Deceased Person Without Hearing Legal Heirs Invalid: Rajasthan High Court
Case Title : Shri Hitesh Patel v. State Of Rajasthan
Case Number : D.B. Civil Writ Petition No. 3194/2026
CITATION : 2026 LLBiz HC (RAJ) 8
The Rajasthan High Court on 26 February, held that assessment proceedings cannot be validly continued or concluded against the legal heirs of a deceased taxpayer under Section 93 of the CGST Act, which limits liability to the estate inherited, unless the authorities comply with mandatory principles of natural justice, including issuance of a proper notice and grant of an opportunity of hearing to the legal representative. A Bench of Acting Chief Justice Sanjeev Prakash Sharma and Justice Baljinder Singh Sandhu found that the assessment order against Late Shri Bhagwan Lal Dangi, in which his son and legal representative Hitesh Patel was affected, failed to adequately set out the factual foundation and reasoning supporting the decision.
Taxpayer Must Be Heard Before 'Draconian' Step Of Provisional Attachment: Rajasthan High Court
Case Title : ARL Infratech Limited v Deputy Commissioner of Income Tax
Case Number : D.B. Civil Writ Petition No. 1217/2026
CITATION : 2026 LiveLaw (Raj) 95
The Rajasthan High Court on 6 March observed that the minimum requirement before invoking provisional attachment under Section 281B of the Income Tax Act, 1961, is to grant the taxpayer an opportunity of hearing to make the payment, or part of it, given the “draconian” nature of the provision. The Division Bench of Acting Chief Justice Sanjeev Prakash Sharma and Justice Sangeeta Sharma was hearing a petition by ARL Infratech Limited challenging an order of the Deputy Commissioner of Income Tax directing provisional attachment of the petitioner's property on the apprehension that a tax demand of around Rs. 1.3 crores might be created.
ITAT
Case Title : Chand Jewellers v. ITO
Case Number : I.T.A. No. 574/Asr/2025
CITATION : 2026 LLBiz ITAT(AMR)23
The Amritsar Bench of the Income Tax Appellate Tribunal (ITAT) last month remanded a demonetisation-related reassessment case to the Assessing Officer for fresh verification of purchase bills, sale bills, and receipt vouchers that were not examined at the assessment stage. A Bench comprising Manoj Kumar Aggarwal, Accountant Member, and Udayan Dasgupta, Judicial Member was hearing an appeal by Chand Jewellers, a partnership firm engaged in gold jewellery business against the confirmation of an addition of Rs. 1.03 crore as "unexplained cash deposits" during the demonetisation period.
Case Title : Hareon Solar Singapore Pvt. Ltd Vs DCIT
Case Number : ITA No.2226/Del/2024
CITATION : 2026 LLBiz ITAT(DEL) 24
The Income Tax Appellate Tribunal at New Delhi has denied capital gains tax exemption to Hareon Solar Singapore Pvt. Ltd. under the India–Singapore Double Taxation Avoidance Agreement, holding that the company was set up solely for claiming the tax benefit. The tribunal comprising Judicial Member Raj Kumar Chauhan and Accountant Member Ramit Kochar held, “Thus, we hold that the assessee company was created for the principal purposes of taking a tax advantage under the India-Singapore DTAA, while otherwise there is no economic substance or commercial justification for routing investment through assessee company based at Singapore. Thus, in the instant case, LOB clause 1 of Article 24A of India-Singapore DTAA is attracted.”
ITAT Mumbai Sets Aside ₹1.14 Crore Transfer Pricing Adjustment For Lack Of Proper FAR Analysis
Case Title : Corporate Worldwide Stay LLP v Assessment Unit, Income-tax Department
Case Number : ITA No. 5940/Mum/2024
CITATION : 2026 LLBiz ITAT(MUM) 25
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) on 6 January set aside a transfer pricing adjustment of Rs. 1.14 crore against Corporate Worldwide Stay LLP, after finding that the revenue authorities had proceeded on assumptions about the firm's functions and risks without a proper FAR analysis. The bench, comprising Judicial Member Anikesh Banerjee and Accountant Member Vikram Singh Yadav remitted to the assessing officer and transfer pricing officer for fresh adjudication.
Case Title : Dharamdas Charitable Trust v. CIT (Exemption), Ahmedabad
Case Number : I.T.A. No. 73/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 26
The Income Tax Appellate Tribunal at Ahmedabad has recently held that a charitable trust cannot be denied approval under Section 80G of the Income Tax Act merely because one of its objects provides for organising Ramkatha, Bhagwat Katha, and similar programmes for raising funds. A coram of Judicial Member Sanjay Garg and Accountant Member Narendra Prasad Sinha observed that object of the trust “cannot be said to be wholly or substantially religious in nature,” and that organising Ramkatha and Bhagwat Katha “cannot be said to be for the purpose of propagating any religion.”
ITAT Chennai Rules Cash Deposits Can Be Set Off Against Earlier Advances, Deletes ₹20 Lakh Addition
Case Title : Dhanabalan Selvamuthu Kumar v. ITO, Ward-1(5), Erode
Case Number : ITA No.1011/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 27
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 2 February deleted an addition of Rs. 20 lakh on a taxpayer out of the total Rs. 39.95 lakh made towards unexplained cash deposits and bank credits, observing that earlier bank deposits or cash advances can be set off against the said deposits. The matter was heard by Judicial Member Manu Kumar Giri and Accountant Member S.R. Raghunatha. The Bench noted that cash deposits of Rs. 20,00,000 in UCO Bank, made by Dhanabalan Selvamuthu Kumar, the assessee, on three different dates, had been treated as unexplained solely because no separate explanation was furnished for these deposits.
ITAT Chennai Cancels Rs 1.5 Lakh Penalty For Delayed Audit Filing, Cites Reasonable Cause
Case Title : Sahana Jewellery Exports Private Limited v. ITO, Corporate Ward-3, Coimbatore
Case Number : ITA No.3474/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 28
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 2 February deleted a penalty of Rs. 1,50,000 imposed on a jewelry export company for delayed filing of its audit report under Section 44AB of the Income-tax Act, 1961. A Bench of Judicial Member Abhy T. Varkey and Accountant Member S.R. Raghunatha, observed that penalty provisions could not to be mechanically invoked and that the assessee was prevented by “reasonable cause.”
Reopening Of Assessment Invalid If AO Fails To Show Reason To Believe: ITAT Chennai
Case Title : Aryan Share & Stock Brokers Ltd. v. ITO, Corporate Ward-1(1), Chennai
Case Number : ITA No.2756/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 29
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 2 February quashed the reopening of assessment against a SEBI-registered stock broker, holding that the Assessing Officer failed to satisfy the “reason to believe” requirement under Section 147 of the Income Tax Act, 1961. Judicial Member Abhy T. Varkey and Accountant Member S.R. Raghunatha observed that the recorded reasons were “extremely scanty and vague.”
They further held: “According to us, the reasons recorded should be clear and unambiguous and should not suffer from any vagueness. The reasons recorded must disclose his mind. Reasons are the manifestation of mind of the AO. The reasons recorded should be self-explanatory and should not keep the assessee guessing for the reasons.”
ITAT Delhi Quashes Tax Revision Against Senior Advocate Mukul Rohatgi For AY 2020–21
Case Title : Mukul Rohatgi vs. Principal Commissioner of Income Tax
Case Number : ITA No. 2427/Del/2025
CITATION : 2026 LLBiz ITAT (DEL) 30
The Delhi Bench of the Income Tax Appellate Tribunal on Monday quashed a revision order passed against Senior Advocate Mukul Rohatgi for Assessment Year 2020–21, holding that the Income Tax Department lacked material to exercise its revision powers for an assessment of Rs.133.46 crore. Section 263 allows a senior tax officer to revise a completed assessment if it is found to be erroneous and prejudicial to the interests of the Revenue. In Rohatgi's case, the Tribunal held that these statutory conditions were not satisfied.
ITAT Mumbai Upholds Fresh Examination of Ambuja Cements' AY 2019–20 Assessment For Lack Of Inquiry
Case Title : Ambuja Cements Limited Vs Principal Commissioner of Income Tax, Mumbai
Case Number : ITA No.3474/MUM/2025
CITATION : 2026 LLBiz ITAT(MUM) 31
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed Ambuja Cements Limited's appeal against a revision order that had set aside its completed tax assessment for fresh verification, holding that the original assessment was passed “without due examination and verification.” The company had challenged the Principal Commissioner of Income Tax's order under Section 263 revising and setting aside its Assessment Year 2019–20 assessment on the ground that the Assessing Officer had failed to verify material issues. The Tribunal has now upheld that revision, meaning the assessment remains set aside and will be examined afresh.
ITAT Delhi Quashes Revision Order Against Studds, Flags Lack of Clear Findings
Case Title : Studds Accessories Limited v. PCIT, Faridabad
Case Number : ITA No. 3570/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 35
The Delhi Bench of the Income Tax Appellate Tribunal has recently set aside a revision order passed against Studds Accessories Limited for Assessment Year 2020–21, holding that the Principal Commissioner failed to show how the assessment was “erroneous as well as pre-judicial to the interest of the revenue.” Studds Accessories Limited is a popular two-wheeler helmet manufacturer. Allowing the appeal, the Bench of Judicial Member Raj Kumar Chauhan and Accountant Member S. Rifaur Rahman said the Principal Commissioner “has not even whispered the mistake” on the detailed submissions made by the assessee.
ITAT Chennai Deletes Penalty for Under-Reporting Of Income After Finding 99% Tax Covered by TDS
Case Title : Shri Santhosh Abraham v. Income Tax Officer, Ward 1, Kancheepuram
Case Number : ITA No. 3950/CHNY/2025 & S.A. No. 137/CHNY/2025
CITATION : 2026 LLBiz ITAT(CHE) 34
The Chennai Bench of the Income Tax Appellate Tribunal has recently deleted a Rs. 2.57 lakh penalty imposed under Section 270A of the Income Tax Act (penalty for under-reporting of income) on an individual salaried taxpayer. The tribunal noted that TDS (tax deducted at source) on the assessee's salary had almost covered 99% of the total tax demand and held that, “When tax liability is covered by TDS, there is no manafide intention on the part of the assessee to conceal any particulars of income or under reporting his income. Therefore, the explanation of the assessee that he was prevented from filing the return of income for the relevant assessment year due to suffering Covid-19 is a bonafide explanation and covered u/s.270A(6)(a) of the Act.”
'Cannot Wear Cap of A Businessman': ITAT Delhi Deletes ₹53.30 Lakh Disallowance Against Zeta
Case Title : Zeta Buildtech Pvt. Ltd. Vs. DCIT
Case Number : ITA No. 3449/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 32
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has granted relief of Rs. 53.30 lakh to Zeta Buildtech Pvt. Ltd., a distributor of liquor and beverages, by deleting disallowances on payments to independent service providers and holding that the Revenue cannot question the commercial wisdom of such expenditure. For Assessment Year 2020–21, Zeta had declared total income of ₹98.48 lakh.The Assessing Officer had disallowed Rs. 31.80 lakh paid to S.P. Jindal Financial Services Limited towards internal audit and MIS services, Rs. 3 lakh paid to Bigthink Media Pvt. Ltd., and Rs. 18.50 lakh paid to S.P. Jindal Marketing Limited. The Commissioner of Income Tax (Appeals) upheld the additions.
Case Title : DCIT Vs. Shri Irfan
Case Number : ITA Nos. 3519 & 3520/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 33
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the Revenue's appeals and upheld deletion of a protective addition of Rs.175.03 crore and an estimated commission addition of about Rs.1.75 crore made against a livestock supplier on allegations of providing accommodation entries to HMA Agro Industries Ltd. The Bench of Judicial Member Vimal Kumar and Accountant Member S. Rifaur Rahman held that once the transactions were found to be genuine business transactions, the additions could not be sustained.
TDS Not Required Where Income Not Chargeable To Tax In India: ITAT Ahmedabad
Case Title : ACIT, Circle-2(1)(1), Ahmedabad v. Ms. Jagson Colorchem Limited
Case Number : ITA No. 1437/Ahd/2024
CITATION : 2026 LLBiz ITAT(AHM) 38
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) has upheld the deletion of a Rs. 5.63 crore disallowance made against Jagson Colorchem Limited, holding that commission paid to foreign agents for services rendered outside India is not chargeable to tax in India. The Bench of Judicial Member T R Senthil Kumar and Accountant Member Narendra Prasad Sinha, observed: “Once the income is not chargeable to tax in India, the question of deducting TDS thereon under the provision of section 195 of the Act and disallowance of the entire payment under the provisions of section 40(a)(i) of the Act does not arise."
ITAT Ahmedabad Deletes ₹9.65 Crore Addition On Demonetisation Cash Deposits Backed by Recorded Sales
Case Title : Bhaumik Jewellers Private Limited v. ITO, Ward-1(1)(2), Ahmedabad
Case Number : ITA No. 1642/Ahd/2024
CITATION : 2026 LLBiz ITAT(AHM) 37
The Ahmedabad Bench of the Income Tax Appellate Tribunal recently held that once purchases are accepted and stock is not disputed, sales cannot be treated as unexplained cash credits merely because the cash was deposited during the demonetisation period. A bench of Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta deleted an addition of Rs.9,65,97,834 made under Section 68 of the Income Tax Act, holding, “Once the purchases are accepted and the stock is not disputed, the sales flowing out of such stock cannot be treated as non-genuine.”
Entire Accommodation Entry Purchases Cannot Be Treated as “Unexplained Cash”: ITAT Mumbai
Case Title : Balaji Bullions And Commodities India Private Limited Vs DCIT, Central Circle 7(1), Mumbai, Aayakar Bhawan, Mumbai, Maharashtra.
Case Number : ITA No. 3755/MUM/2025 Assessment Year: 2017-18
CITATION : 2026 LLBiz ITAT(MUM) 42
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) on 23 February, held that even if purchases are accommodation entries, once they are recorded in regular books of account and routed through banking channels, they cannot be treated as “unexplained expenditure” under Section 69C of the Income Tax Act. The Bench, comprising Accountant Member Om Prakash Kant and Judicial Member Ms. Kavitha Rajagopal, was hearing cross-appeals in the case of Balaji Bullions and Commodities India Pvt. Ltd. for Assessment Year 2017–18.
ITAT Mumbai Holds CSR Donations Deductible Under Section 80G, Allows Aditya Birla's PF Contributions
Case Title : Aditya Birla Sun Life AMC Limited v. DCIT Circle-6(1)(1), Mumbai
Case Number : ITA Nos. 6663, 6701, 6702 & 6703/Mum/2025
CITATION : 2026 LLBiz ITAT(MUM) 39
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) on 6 February, observed that CSR donations to approved institutions qualify for deduction under Section 80G of the Income Tax Act, 1961. The Bench also clarified that employees' provident fund contributions cannot be disallowed if deposited within the statutory due date. In the consolidated appeals filed by Aditya Birla Sun Life AMC Limited, the Bench of Judicial Member Amit Shukla and Accountant Member Makarand Vasant Mahadeokar, partly allowed the appeals relating to assessment years 2017-18, 2018-19, 2022-23, and 2023-24.
Case Title : Tata Chemicals Ltd. v. Dy. CIT-2(3)(1), Mumbai
Case Number : ITA No. 7912/MUM/2019
CITATION : 2026 LLBiz ITAT(MUM) 36
The Income Tax Appellate Tribunal has upheld a Rs. 146.73 crore interest disallowance against Tata Chemicals Ltd and affirmed a Rs. 3.62 crore transfer pricing adjustment, ruling against the company on the two biggest issues in its 2015-16 assessment. A Bench of Judicial Member Rahul Chaudhary and Accountant Member Om Prakash Kant said, “In view of the foregoing discussion, we find no infirmity in the order of the Dispute Resolution Panel affirming the action of the Transfer Pricing Officer in re-characterising the preference share investment as a loan transaction and benchmarking the same accordingly.”
Case Title : Income Tax Officer v. Ratna Aggarwal
Case Number : ITA No.21/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 40
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the Revenue's appeal against an individual taxpayer, Ratna Aggarwal, holding that, in the facts of the case, a property received pursuant to a family settlement was not taxable under Section 56(2)(vii)(b) of the Income Tax Act. Section 56(2)(vii)(b) provides that where an individual receives immovable property without consideration from a person who is not a specified "relative," the stamp duty value of such property is taxable as income from other sources.
TDS On Consultant Doctors To Be Deducted As Professional Fees, Not Salary: ITAT Delhi
Case Title : DCIT v. Agilus Diagnostics Ltd.
Case Number : ITA No.2836/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 41
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the Revenue's appeal against Agilus Diagnostics Ltd and held that consultant doctors engaged by the company were independent professionals, not employees. Agilus Diagnostics Ltd. is engaged in the business of establishment, maintenance and management of clinical reference laboratories in India.
Tax Exemption Cannot Be Denied For Mere Registration Of Land In Trustees' Names: ITAT Chennai
Case Title : The ACIT (Exemptions), Chennai v. Everwin Educational & Charitable Trust
Case Number : ITA No.2811/Chny/2024
CITATION : 2026 LLBiz ITAT(CHE) 43
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 24 February, held that exemption under Section 11 of the Income Tax Act cannot be denied to Everwin Educational & Charitable Trust, merely because land acquired for construction of a school was registered in the names of its trustees. A Bench comprising Judicial Member Aby T. Varkey and Accountant Member Amitabh Shukla dismissed the Revenue's appeal for Assessment Year 2016-17 and upheld the order of the Commissioner (Appeals), who had deleted the addition.
Case Title : Ganna Vikas Parishad v. Assessment Unit, Income Tax Department
Case Number : ITA No.7788/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 45
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has remanded to the Assessing Officer the case of Ganna Vikas Parishad, Nanauta, holding that the authorities below had not examined the constitution and activities of the taxpayer while sustaining an addition of Rs 32,91,119 and denying its claim of exemption. Judicial Member C.N. Prasad observed that although he “could not find fault with the reasoning of the Ld. CIT(A) in sustaining the addition,” the authorities had failed to examine the nature of the assessee.
ITAT Delhi Remands Dispute Over ₹32.13 Lakh Addition Based On Seized Excel Sheet
Case Title : Anuradha Singh v. Circle 5(1)(1), Gautam Budh Nagar
Case Number : ITA No.8303/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 44
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has restored to the Assessing Officer a dispute in relation to the addition of Rs 32.13 lakh made against a Greater Noida taxpayer in connection with the purchase of a commercial unit. The tribunal directed that all material relied upon must be furnished to the taxpayer and cross-examination allowed if any statements are used to sustain the addition.
Case Title : Verizon Communications India P. Ltd. v. Additional CIT, Special Range-9, New Delhi
Case Number : ITA No. 442/DEL/2017
CITATION : 2026 LLBiz ITAT(DEL) 47
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) held that the Transfer Pricing Officer (TPO) could not reject a taxpayer's limited risk model without citing any comparable uncontrolled transactions and partly set aside a transfer pricing adjustment of Rs. 83.49 crore against Verizon Communications India Pvt. Ltd., restricting the adjustment to Rs. 23.81 crore. A Bench comprising Accountant Member S. Rifaur Rahman and Judicial Member Anubhav Sharma upheld the company's claim for deduction under Section 80-IA and deleted the disallowance under Section 40(a)(i) relating to payments made to foreign telecom operators.
Case Title : KP Diamonds (P) Ltd. v. Income Tax Officer
Case Number : ITA No.6351/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 48
The New Delhi Income Tax Appellate Tribunal (ITAT) has held that cash sales recorded during the demonetisation period cannot be treated as unexplained income merely on the basis of suspicion or human probabilities, when such sales are duly reflected in audited books of account and supported by stock records, invoices, and VAT returns. The bench consisting of Judicial Member Anubhav Sharma and Accountant Member Manish Agarwal, was dealing with an appeal filed by M/s KP Diamonds (P) Ltd., a trader in diamonds and gold jewellery, for the assessment year 2017–18.
Case Title : Nishant Anand v. The Assessing Officer Delhi
Case Number : ITA No.6622/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 50
The New Delhi Income Tax Appellate Tribunal (ITAT) has recently held that payments towards credit card dues cannot be added as unexplained expenditure under Section 69C of the Income Tax Act when the assessee is able to satisfactorily explain the source of such payments with supporting evidence. A single bench of Judicial Member CN Prasad, was dealing with the appeal filed by an individual assessee for Assessment Year 2023–24, where the Assessing Officer had treated credit card payments of Rs 11.32 lakh as unexplained expenditure, invoking Sections 69C read with 115BBE of the Income Tax Act.
'No Whisper Of Tangible Material': ITAT Delhi Quashes Reassessment Against Vedanta For AY 2010-11
Case Title : Vedanta Limited v. Assistant Commissioner of Income Tax, Circle 26(1), New Delhi
Case Number : ITA Nos. 2405/Del/2019 & 2250/Del/2019
CITATION : 2026 LLBiz ITAT(DEL) 51
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has quashed reassessment proceedings against Vedanta Limited for Assessment Year 2010-11. It held that the reopening beyond four years was without jurisdiction as it was not based on any fresh tangible material. A coram of Judicial Member Pawan Singh and Accountant Member Brajesh Kumar Singh observed that “there is no whisper of any tangible material which came to the possession of the assessing officer subsequent to the passing of the assessment order u/s 143(3) of the Act on 28.01.2013 or there was any failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment in the return of income for that assessment year in respect of the above two issues on which the assessment was reopened.”
Case Title : Varun Beverages Limited v. Assistant Commissioner of Income Tax, Central Circle-7, New Delhi
Case Number : ITA Nos. 3476/Del/2025, 3477/Del/2025 & 3478/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 49
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has held that no transfer pricing adjustment is warranted where the interest charged on loans advanced to associated enterprises exceeds the internal Comparable Uncontrolled Price (CUP). The bench comprising Judicial Member Yogesh Kumar U.S. and Accountant Member Manish Agarwal deleted the entire transfer pricing adjustment of Rs 3,42,31,778 for Assessment Year 2017-18 in the case of Varun Beverages Limited, including Rs 2,84,45,221 towards interest on foreign currency loans advanced to overseas associated enterprises and Rs 57,86,557 towards notional interest on outstanding receivables.
No Disallowance Of Interest In Absence of Nexus Between Borrowed Funds And Advances: ITAT New Delhi
Case Title : M/s Shivam Agrioils Pvt. Ltd. v. Deputy Commissioner of Income Tax
Case Number : ITA No. 1030/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 46
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 27 February, held that interest disallowance under Section 36(1)(iii) of the Income-tax Act, 1961 cannot be sustained in the absence of a nexus between borrowed funds and interest-free advances, particularly where such advances were granted in years preceding the borrowings and were supported by commercial expediency. A Bench comprising Judicial Member Satbeer Singh Godara and Accountant Member Amitabh Shukla deleted the addition of Rs. 43,86,674 made towards alleged diversion of interest-bearing funds and allowed the appeal filed by Shivam Agrioils Private Limited (the taxpayer) for Assessment Year 2018-19.
Air India SATS Entitled To Tax Benefits On Ground & Cargo Handling Income: ITAT Delhi
Case Title : ACIT v. M/s Air India Sats Airport Services Pvt. Ltd.
Case Number : ITA No. 5026/Del/2016
CITATION : 2026 LLBiz ITAT(DEL) 52
On 26 February, the New Delhi Income Tax Appellate Tribunal (ITAT) held that Air India SATS Airport Services Pvt. Ltd.'s income from airport ground handling and cargo handling operations qualifies for tax incentives available to eligible infrastructure-related service providers. A Bench of Judicial Member Satbeer Singh Godara and Accountant Member Naveen Chandra heard the Revenue's appeal, which challenged the deduction claimed by Air India SATS under Section 80-IA of the Income Tax Act on income derived from airport ground handling and cargo handling operations.
Notice Issued By Officer Without Jurisdiction Cannot Sustain Assessment: ITAT Quashes Assessment
Case Title : Jagruti Kirti Shah v. Assistant Commissioner of Income Tax, Circle 23(1), Mumbai
Case Number : ITA Nos. 5844/Mum/2025 & 6125/Mum/2025
CITATION : 2026 LLBiz ITAT(MUM) 53
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) on 26 February quashed an assessment against taxpayer Jagruti Kirti Shah, holding that the notice under Section 143(2) of the Income Tax Act was issued by an officer lacking jurisdiction as per the Central Board of Direct Taxes (CBDT) Instruction No. 1 of 2011. Instruction 1 prescribes the officer-level jurisdiction for issuing scrutiny notices based on the assessee's income and category. The Bench, comprising Judicial Member Rahul Chaudhary and Accountant Member Bijayananda Pruseth, allowed the taxpayer's additional ground and set aside the assessment order dated 24 December 2018 passed under Section 143(3) of the Income Tax Act.
Penalty Invalid Where AO Issues Stereotypical Notice Without Specifying Charge: ITAT Delhi
Case Title : Ms. Deepti Goel v. Income Tax Officer
Case Number : ITA No. 6069/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 54
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 25 February quashed an income tax penalty imposed on a taxpayer, after finding that the Assessing Officer issued a stereotypical penalty notice without specifying the exact charge under the Income Tax Act. A Tribunal Bench comprising Judicial Member Yogesh Kumar U.S. and Accountant Member Renu Jauhri held that a notice issued must clearly state whether the penalty proceedings are initiated for “concealment of income” or “furnishing inaccurate particulars of income.” Failure to specify the charge renders the penalty proceedings invalid.
ITAT Delhi Quashes Reassessment Against Lalit Modi Over Credit Card, Private Jet Expenses
Case Title : Lalit Kumar Modi v. Deputy Commissioner of Income Tax
Case Number : ITA No.1636/DEL/2023
CITATION : 2026 LLBiz ITAT(DEL) 55
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has quashed reassessment proceedings initiated against former IPL commissioner Lalit Kumar Modi over alleged unexplained credit card expenditure and private jet costs. The tribunal held that reassessment cannot be initiated while regular scrutiny assessment proceedings are still pending. A bench of Judicial Member Vikas Awasthy and Accountant Member Brajesh Kumar Singh held that the reassessment was without jurisdiction. It observed that initiating reassessment in such circumstances amounted to impermissible parallel proceedings.
ITAT Delhi Upholds Deletion Of ₹1.34 Crore Tax Addition Against NDTV
Case Title : DCIT v. New Delhi Television Ltd. & New Delhi Television Ltd. v. DCIT
Case Number : ITA No.1564/Del/2016 & ITA No.1623/Del/2016
CITATION : 2026 LLBiz ITAT(DEL) 56
The Income Tax Appellate Tribunal (ITAT) at Delhi on Friday upheld relief granted to New Delhi Television Ltd. (NDTV) in a dispute over a Rs 1.34 crore disallowance under Section 14A of the Income Tax Act for the assessment year 2010–11. The tribunal held that expenditure cannot be disallowed under the provision where the taxpayer has not earned any tax-exempt income during the relevant year. A bench comprising Judicial Member Madhumita Roy and Accountant Member Manish Agarwal dismissed the Income Tax Department's appeal challenging the deletion of the disallowance.
ITAT Delhi Upholds Tax Incentive For Big Babol, Mentos Maker Perfetti's Uttarakhand Unit
Case Title : ACIT v. Perfetti Van Melle India Pvt. Ltd.
Case Number : ITA No. 623/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 57
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has upheld the order allowing confectionery manufacturer Perfetti Van Melle India Pvt. Ltd. to claim tax deduction under Section 80-IC of the Income Tax Act on profits from its Rudrapur manufacturing unit in Uttarakhand. A bench of Judicial Member Anubhav Sharma and Accountant Member Manish Agarwal dismissed the Revenue's appeal and upheld the order of the Commissioner of Income Tax (Appeals) allowing the deduction.
Builder Incentives For Timely Payment Cannot Be Taxed As 'Income from Other Sources': ITAT Delhi
Case Title : Sh. Satya Prasan Rajguru v. DCIT Circle
Case Number : ITA No. 2550/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 58
The New Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 26 February held that rebates or concessions provided by a builder under an apartment buyer's agreement cannot be treated as taxable income under Section 56 of the Income Tax Act, 1961. A Bench comprising Judicial Member Anubhav Sharma and Accountant Member Manish Agarwal was hearing the appeal filed by Satya Prasan Rajguru against the order of the National Faceless Appeal Centre, which had confirmed the additions made by the Assessing Officer for Assessment Year 2021–22.
ITAT Mumbai Deletes Additions On Individual Taxpayer, Rules Cash Redeposits Not “Unexplained”
Case Title : Nitinkumar Pravinchandra Kacharia v. DCIT
Case Number : ITA No. 8597 & 8598/MUM/2025
CITATION : 2026 LLBiz ITAT(MUM) 59
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) on 25 February deleted additions made on cash deposits in the bank account of an individual taxpayer, holding that redeposits of earlier withdrawals cannot be treated as unexplained money in the absence of evidence that the cash was used elsewhere. A Bench comprising Accountant Member Om Prakash Kant and Judicial Member Kavitha Rajagopal allowed the appeals of the taxpayer, Nitinkumar Pravinchandra Kacharia, for Assessment Years 2022-23 and 2023-24.
Partial Use Of Director's Farmhouse For Business Does Not Bar Depreciation Claim: ITAT Delhi
Case Title : DCIT v. Malhotra Cables Pvt. Ltd
Case Number : ITA Nos. 1317-1324/Del/2025; 1108, 1107, 1097 & 1102/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 60
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 11 March 2026 upheld the deletion of disallowances relating to repair expenses and depreciation claimed on a farmhouse owned by Jagadish Chander Malhotra, Director of Malhotra Cables Pvt. Ltd, after finding that part of the premises was used for business purposes. A Bench comprising Judicial Member Challa Nagendra Prasad and Accountant Member M. Balaganesh affirmed the findings of the Commissioner of Income Tax (Appeals) [CIT(A)], which had allowed the expenses.
ITAT Ahmedabad Grants Digvijay Lions Foundation Final Chance For 12A Renewal With ₹10,000 Cost
Case Title : Digvijay Lions Foundation v. Commissioner of Income Tax (Exemption)
Case Number : ITA No. 169/Ahd/2026
CITATION : 2026 LLBiz ITAT(DEL) 61
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 25 February granted Digvijay Lions Foundation a final opportunity to furnish documents for renewal of its charitable registration under Section 12A of the Income Tax Act. The Bench, comprising Judicial Member Suchitra Kamble and Accountant Member Narendra Prasad Sinha, was hearing the foundation's appeal against rejection of its renewal application by the Commissioner of Income Tax (Exemption), Ahmedabad.
Goodwill Arising From Amalgamation Eligible For Depreciation In Subsequent Years: ITAT Ahmedabad
Case Title : ACIT v. Unicorn Packaging LLP & Ors.
Case Number : ITA Nos. 893 to 898/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 62
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) held that depreciation on goodwill arising from an amalgamation can be continued in subsequent years, as long as it pertains to the same intangible asset already recognized in the foundational year. A Bench comprising Judicial Member Sanjay Garg and Accountant Member Narendra Prasad Sinha upheld the deletion of disallowance of depreciation claimed by Unicorn Packers Pvt. Ltd. (now part of the taxpayer LLP) on goodwill arising from its amalgamation with Urmin Marketing Pvt. Ltd.
Charitable Registration Cannot Be Cancelled For Disputed Transactions Alone: ITAT New Delhi
Case Title : Richmond Educational Society Vs DCIT/ACIT
Case Number : ITA No. 4779/Del/2025 (Assessment Year: 2024-25)
CITATION : 2026 LLBiz ITAT(DEL) 63
The New Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 11 March held that the registration of a charitable institution under Section 12AB of the Income Tax Act cannot be cancelled merely on the basis of alleged irregularities in certain financial transactions, as long as the core charitable activities continue to be genuine. A Bench comprising Judicial Member Challa Nagendra Prasad and Accountant Member M. Balaganesh restored the charitable registration of Richmond Educational Society and set aside the order of the Principal Commissioner of Income Tax, observing that financial transactions alone cannot justify cancellation.
ITAT Ahmedabad Upholds 100% Deduction After Expansion Of Sintex's Himachal Unit
Case Title : DCIT v. Sintex Industries Ltd.
Case Number : ITA No. 715/Ahd/2025 with Cross Objection No. 88/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 64
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) has upheld the eligibility of Sintex Industries Ltd. to claim 100% deduction on profits under Section 80-IC of the Income Tax Act even after the initial five-year period where the eligible unit had undertaken substantial expansion. The tribunal coram of Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta dismissed the Revenue's appeal challenging the deletion of an addition of Rs 59.53 crore made by the Assessing Officer for Assessment Year 2010-11.
Escaped Income Must Include Real Taxable Income, Not Aggregate Value: ITAT Ahmedabad
Case Title : Rupinder Singh Duggal v. Income Tax Officer
Case Number : ITA No: 1921/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 65
The Ahmedabad Income Tax Appellate Tribunal (ITAT) on 16 March, held that the expression “income chargeable to tax which has escaped assessment” under Section 149 of the Income Tax Act refers to the actual taxable income sought to be brought to tax, and not the gross value of underlying transactions. A Bench comprising Judicial Member T.R. Senthil Kumar quashed the reassessment proceedings for Assessment Year 2017–18, holding that the assumption of jurisdiction under Section 148 was invalid because the alleged escaped income did not meet the statutory threshold of Rs.50 lakhs.
ITAT Ahmedabad Grants Partial Relief To Arrow Clothing In Demonetisation Cash Deposit Addition Case
Case Title : Arrow Clothing Pvt. Ltd. v. Income Tax Officer
Case Number : ITA No. 2532/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 66
The Income Tax Appellate Tribunal (ITAT) at Ahmedabad partly allowed an appeal of Arrow Clothing Pvt. Ltd, holding that addition for unexplained cash deposits during demonetisation was justified, but the taxpayer was entitled to credit for opening cash balance and prior bank withdrawals. A coram of Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta held that anomalies were found only in the explanation relating to cash sales and not in the opening cash balance or bank withdrawals of Rs 11.38 lakh.
Case Title : Deputy Commissioner of Income Tax Circle v. Blend Financial Services Limited
Case Number : ITA No. 8088/MUM/2025
CITATION : 2026 LLBiz ITAT(MUM) 67
The Mumbai Income Tax Appellate Tribunal (ITAT) has upheld the deletion of disallowance of foreign travel expenses made against a company engaged in global management and financial consultancy services. The court held that in the facts of the case, the expenditure could not be disallowed merely because no income was directly earned from certain countries visited during the relevant year where the taxpayer had produced material showing business purpose and nexus with its activities.
ITAT Ahmedabad Sets Aside Ad-Hoc Expense Disallowance As AO Failed To Point Out Defects
Case Title : Raghani Tradelink v. The Income Tax Officer
Case Number : ITA No.1692/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 68
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) has recently set aside ad-hoc disallowances made against Raghani Tradelink, a commission agent engaged in facilitating sales of sarees, suits, and garments across India, holding that additions towards sub-brokerage and administrative expenses cannot be sustained when the Assessing Officer fails to point out specific discrepancies in the evidence produced by the assessee. The coram comprising Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta was dealing with the appeal filed by the taxpayer for the Assessment Year 2020–21.
Case Title : Deputy Commissioner of Income Tax v. M/s Zen Industries Pvt. Ltd.
Case Number : 888/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 69
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) has upheld the deletion of tax additions made against a mouth freshener manufacturing company, finding that the additions were founded only on loose sheets that lacked basic particulars and were unsupported by any corroborative evidence to establish unaccounted transactions. The case arose from a search conducted on a third party, during which certain handwritten loose sheets were found in the possession of an employee of the taxpayer company, Zen Industries Pvt. Ltd.
Lower Cost Of Acquisition Without Justification Not Warranted: ITAT Ahmedabad
Case Title : Nirmalaben Kamleshbhai Contractor v. Assessment Unit, Income Tax Department
Case Number : ITA No.1911/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 70
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 27 February held that adopting a lower deemed cost of acquisition than that accepted for co-owners, without justification, was not warranted. A Tribunal Bench comprising Vice-President Dr. B.R.R. Kumar and Judicial Member Suchitra Kamble allowed the appeal of Nirmalaben Kamleshbhai Contractor and allowed deduction under Section 54EC, finding the investment was made within the prescribed period.
Case Title : Shilpa Shetty Kundra vs. DCIT, CC-5(2), Mumbai
Case Number : ITA No.996/M/2025
CITATION : 2026 LLBiz ITAT(MUM) 71
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has recently asked actor Shilpa Shetty Kundra to submit “complete details/clarifications and documents” to justify a Rs 12.54-crore gift received from her husband Raj Kundra, while remanding the matter to the Jurisdictional Assessing Officer for fresh examination under Section 68 of the Income Tax Act, 1961. Judicial Member Narender Kumar Choudhry and Accountant Member Prabhash Shankar said the material on record was not sufficient to establish the genuineness of the transaction and required further factual verification. The Bench noted that Shetty had not fully discharged the initial burden placed on her under the Act.
Double Taxation Of Share Application Money Impermissible: ITAT Kolkata
Case Title : Income Tax Officer, Ward 9(1), Kolkata v. Littlestar Securities Private Limited
Case Number : ITA No. 694/KOL/2025
CITATION : 2026 LLBiz ITAT(KOL) 72
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) on 6 March, held that taxing share application money already taxed in the hands of investor companies amounts to impermissible double addition. The Bench comprising Accountant Member Rajesh Kumar and Judicial Member Pradip Kumar Choubey dismissed the Revenue's appeal against Littlestar Securities Pvt. Ltd. for Assessment Year 2012-13 and upheld the deletion of Rs. 27.63 crore added as unexplained cash credit.
Ad-Hoc Estimation of Income Without Rejecting Books of Account Not Permissible: ITAT Kolkata
Case Title : Rakhi Mondal v. Assessment Unit, Income Tax Department (NFAC)
Case Number : ITA No. 2151/Kol/2025
CITATION : 2026 LLBiz ITAT(KOL) 73
The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) on 17 February 2026 held that income cannot be estimated on an ad-hoc basis without first rejecting the books of account, and set aside an addition made on that basis while quashing the reassessment proceedings. The Bench comprising Accountant Member Rajesh Kumar and Judicial Member Pradip Kumar Choubey allowed the appeal filed by Rakhi Mondal for Assessment Year 2017-18. It held: “the said reopening has been done without meeting the specific requirement as provided u/s 149(1)(b) of the Act. Therefore, we quash reopening of assessment.”
Bona Fide Delay In Filing Tax Appeal Caused By Pursuing Alternate Remedy Condonable: ITAT Chennai
Case Title : M/s. A-One Leathers v. Assistant Commissioner of Income Tax, Non-Corporate Circle 4(1), Chennai
Case Number : ITA No. 4148/CHNY/2025
CITATION : 2026 LLBiz ITAT(KOL) 74
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) held that a delay of 1036 days in filing an appeal could be condoned when it arose from pursuing an alternate remedy and was not deliberate. A Bench comprising Vice President George George K and Accountant Member S.R. Raghunatha, in an appeal filed by A-One Leathers for Assessment Year 2015-16, remanded the matter to the Assessing Officer to examine a claim of double taxation. It observed: “The delay… neither wanton nor willful but only on account of the party pursuing an alternate remedy under the rectification route.”
Case Title : Vinayaga Fireworks v. DCIT
Case Number : ITA No. 2282/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 75
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 3 March 2026 held that cash deposits made during the demonetisation period cannot be treated as unexplained under Section 68 of the Income Tax Act, 1961, if corresponding sales are accepted and recorded in the books of account. A Bench comprising Judicial Member S.S. Viswanethra Ravi and Accountant Member S.R. Raghunatha allowed an appeal by Vinayaga Fireworks, a Sivakasi-based cracker manufacturer, against an order of the Commissioner of Income Tax (Appeals), NFAC. It observed: “Unless the sales are held to be bogus, the corresponding sales receipts cannot be treated as unexplained cash credits.”
ITAT Mumbai Deletes ₹48.97 Lakh Tax Addition Against Zee Entertainment For Failing To Record Reasons
Case Title : Zee Entertainment Enterprises Limited v. DCIT
Case Number : ITA No.6872/Mum/2025 & ITA No.6873/Mum/2025
CITATION : 2026 LLBiz ITAT(MUM) 76
The Income Tax Appellate Tribunal (ITAT) at Mumbai has recently given relief to Zee Entertainment Enterprises Ltd by deleting a Rs 48.97 lakh tax addition under Section 14A of the Income Tax Act, 1961, which deals with expenses linked to earning tax-free income. The Tribunal held that tax officers cannot recalculate such expenses without first clearly explaining why they disagree with the company's own calculation. A coram comprising Judicial Member Anikesh Banerjee and Accountant Member Arun Khodpia was hearing appeals filed by Zee against orders of the Commissioner of Income Tax (Appeals) under Section 250, the provision that governs the first stage of tax appeals.
Case Title : Income Tax Officer v. Udayan Mandavia
Case Number : I.T.A. No.154/Ahd/2026
CITATION : 2026 LLBiz ITAT(AHM) 77
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) has dismissed the Department's appeal in a dispute over the applicable tax rate on unexplained income, holding that the enhanced 60% tax under Section 115BBE cannot be applied to Assessment Year 2017–18 and that such a change cannot be made through rectification under Section 154. Section 115BBE of the Income Tax Act, 1961, imposes a steep penal tax rate on unexplained income, such as cash credits, investments, or assets found during searches or assessments.
Case Title : State Bank of India Bhavnagar Para Branch v. Income Tax Officer
Case Number : I.T.A. No.453&454/Ahd/2026
CITATION : 2026 LLBiz ITAT(AHM) 78
The Ahmedabad Income Tax Appellate Tribunal (ITAT) has held that State Bank of India (SBI) cannot be treated as an “assessee in default” for failure to deduct tax at source on Leave Fare Concession (LFC) payments made to its employees, where such non-deduction was in compliance with binding interim orders of a High Court. A coam of Judicial Member Siddhartha Nautiyal and Accountant Member Narendra Prasad Sinha observed that, during the relevant period, the bank was bound by interim orders of the Madras High Court, which had directed that LFC payments would not be treated as income and no tax was required to be deducted at source.
ITAT Delhi Dismisses Multiple Revenue Appeals Against Make My Trip Across TP, TDS Issues
Case Title : DCIT, New Delhi vs. M/s. Make My Trip India Pvt. Ltd.
Case Number : ITA No.5095/Del/2014
CITATION : 2026 LLBiz ITAT(AHM) 79
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed a batch of appeals filed by the Revenue against MakeMyTrip India Pvt. Ltd. It held that advertisement, marketing, and promotion (AMP) expenditure cannot be treated as an international transaction where the Indian entity owns the brand and upheld deletion of a Rs. 31.81 crore transfer pricing adjustment. The bench comprising Judicial Member C.N. Prasad and Accountant Member M. Balaganesh was dealing with appeals arising from orders of the Commissioner of Income Tax (Appeals). The matters related to assessment years 2009–10, 2011–12, and 2012–13 to 2015–16.
Overall Assessment Time Limit Applies Even In Dispute Resolution Panel Cases: ITAT New Delhi
Case Title : BT India Pvt. Ltd. v. ACIT, Circle-4(2), Delhi
Case Number : ITA Nos. 533 & 1701/Del/2022 (ITAT Delhi)
CITATION : 2026 LLBiz ITAT(DEL) 79
The Delhi Bench of the Income Tax Appellate Tribunal has ruled that final assessment orders under Section 144C (DRP route) must comply with the overarching time limit under Section 153 (assessment deadline), holding that orders passed beyond this limit are time-barred. A coram comprising Judicial Member Vikas Awasthy and Accountant Member Sanjay Awasthy was dealing with appeals filed by BT India Pvt. Ltd. for Assessment Years 2017-18 and 2018-19, wherein the primary issue was whether the assessment orders were barred by limitation.
Reassessment Beyond Three Years Without PCCIT Approval Invalid: ITAT Chennai
Case Title : Vasanthi Ragunathan v. The ITO Ward
Case Number : ITA No.2896/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 80
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 25 March held that reassessment proceedings initiated beyond three years from the end of the relevant assessment year are invalid if the Assessing Officer does not obtain prior approval from the Principal Chief Commissioner of Income Tax (PCCIT), as mandated under the Income Tax Act. The Bench, comprising Judicial Member Aby T. Varkey and Accountant Member S.R. Raghunatha, set aside the reassessment notice issued against Vasanthi Ragunathan, observing: “the notice under section 148 is dated 13.04.2022, which event is undisputedly beyond the period of 3 years from the end of the relevant AY; and therefore as per the provisions of Section 151 of the Act, the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT) before issuing the ibid notice. However, in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT), Coimbatore, while issuing notice under section 148 and therefore the notice is found to be in defiance to prescription given in section 151 of the Act and hence it is invalid in eyes of law.”
Disallowance Irrelevant Where Tax Liability Arises Under MAT: ITAT Ahmedabad
Case Title : Shalby Ltd. v. Principal Commissioner of Income Tax
Case Number : ITA No. 1227/AHD/2025
CITATION : 2026 LLBiz ITAT(AHM) 81
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 26 March, reiterated that a disallowance computed under Rule 8D of the Income Tax Rules cannot be imported into the computation of book profit under the Minimum Alternate Tax (MAT) provisions. The Bench, comprising Judicial Member Suchitra Kamble and Accountant Member Narendra Prasad Sinha, allowed the appeal filed by Shalby Ltd., observing that even if the alleged disallowance were made, it would not impact the taxpayer's liability, as the tax for the relevant assessment year arose entirely under the MAT provisions.
No TDS Under Section 194-IA On Rural Agricultural Land Transactions: ITAT Ahmedabad
Case Title : The Income Tax Officer v. Tarun Santramdas Varma
Case Number : I.T.A. No.2549/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 82
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) 26 March, held that buyers of rural agricultural land are not required to deduct TDS under Section 194-IA of the Income Tax Act, and interest under Section 201(1A) is not leviable. The Bench, comprising Vice-President Dr. B.R.R. Kumar and Judicial Member Suchitra Kamble, dismissed the Revenue's appeal while confirming that Tarun Santramdas Varma (taxpayer) did not owe TDS on certain rural agricultural land transactions.
OTHER DEVELOPMENTS
Interest On Motor Accident Compensation To Be Tax-Free Under Budget Proposal
Interest received on compensation awarded by Motor Accident Claims Tribunals may soon be taken out of the income-tax net. While presenting the Union Budget 2026–27, Finance Minister Nirmala Sitharaman announced a proposal to exempt such interest from tax and remove the requirement of tax deduction at source.
Budget 2026-27 Proposes Penalty Relief, Decriminalisation And Litigation Reduction In Income Tax Law
The Union Budget 2026–27 on Sunday proposed wide-ranging changes to the income tax penalty and prosecution framework, including immunity schemes, decriminalisation of certain offences and procedural measures to reduce litigation. Presenting her direct tax proposals, Finance Minister Nirmala Sitharaman said, “Multiplicity of proceedings are a hindrance to the ease of doing business.” She proposed to “integrate assessment and penalty proceedings by way of a common order for both.”
Budget 2026–27 Keeps Income Tax Slabs And Standard Deduction Unchanged
Finance Minister Nirmala Sitharaman on Sunday presented her ninth Union Budget since taking charge in 2019, keeping income tax slabs under the new tax regime unchanged from changes made last year
Union Budget 2026–27: Buyback Proceeds To Be Taxed As Capital Gains, Promoters Face Additional Levy
The Union Budget 2026–27 has introduced a significant reform in the taxation of share buybacks by shifting the tax incidence to shareholders and aligning buyback income with the capital gains framework. Under the new proposal, proceeds received by all categories of shareholders, including retail investors, institutional investors, and foreign shareholders from share buybacks will be taxed as capital gains, instead of being subject to a separate buyback distribution tax at the company level. This marks a departure from the earlier regime, where companies had to bear the tax burden and shareholders largely received tax-exempt income.
Budget 2026-27: Centre Proposes MCA–CBDT Panel To Integrate ICDS Into IndAS
The Union Budget of 2026 has proposed the constitution of a Joint Committee of the Ministry of Corporate Affairs and the Central Board of Direct Taxes (CBDT) to incorporate the requirements of the Income Computation and Disclosure Standards (ICDS) into the Indian Accounting Standards (IndAS).
Budget Proposes 14% Minimum Alternate Tax Final Levy For Companies Opting New Regime From April 2026
The Union Budget 2026–27 on Sunday proposed changes to the Minimum Alternate Tax (MAT) regime applicable to companies, to take effect from April 1, 2026, alongside the implementation of the Income Tax Act, 2025. Presenting the budget, Finance Minister Nirmala Sitharaman said, “I propose to make Minimum Alternate Tax a final tax for companies opting for the new tax regime.”
Union Budget 2026: FM Proposes Major Income Tax Changes
Presenting the Union Budget 2026, the Finance Minister Nirmala Sitharaman proposed the replacement of the Income Tax Act, 1961 with a new Income Tax Act, 2025, to come into force from April 1, 2026, alongside a series of reforms to the direct-tax regime. The Finance Minister said a comprehensive review of the six-decade-old law, announced in July 2024, had been completed in record time. Simplified Income Tax Rules and new return forms will be notified shortly, with the stated objective that “ordinary citizens can comply without difficulty”.
Any Delay In Income Tax Audit Report May Attract ₹75,000 Late Fee, Proposes Finance Bill 2026
A single day's delay in furnishing a tax audit report may attract a fee of ₹75,000 under the proposed Income-tax Act, 2025, as per the scheme set out in the Finance Bill, 2026. Under the existing law, failure to comply with tax audit requirements attracted a penalty linked to turnover, capped at ₹1.5 lakh, and the penalty could be waived if the taxpayer showed a reasonable explanation for the delay.
Budget 2026-27: No TAN Needed For Resident Buyers To Deduct TDS On Property Purchases From NRIs
As per a proposal in the Union Budget 2026 tabled by Finance Minister Nirmala Sitharaman today, resident individuals and Hindu Undivided Families (HUFs) purchasing immovable property from a non-resident (NRI) will no longer be required to obtain a Tax Deduction and Collection Account Number (TAN) for the purpose of deducting tax at source. Instead, the tax deducted can be deposited using the Permanent Account Number (PAN) of the buyer.
Budget 2026-27 Proposes Tax Relief On Compensation Received For Compulsory Land Acquisition
In the Union Budget 2026, the Finance Minister has proposed to exempt income in respect of any award or agreement arising from the compulsory acquisition of land under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act) from income tax, with effect from Assessment Year 2026–27. Under the existing framework, Schedule III of the Income-tax Act provides certain exemptions in respect of capital gains, but does not expressly cover all forms of compensation received on the compulsory acquisition of land.
Budget 2026-27 Introduces One-Time Disclosure Scheme For Small Taxpayers' Undisclosed Foreign Assets
The Union Budget 2026 has introduced the Foreign Assets of Small Taxpayers Disclosure Scheme, 2026 through the Finance Bill, 2026. The scheme proposes to offer a one-time opportunity for eligible taxpayers to come forward and declare undisclosed foreign assets or foreign income. On making a valid declaration and payment, taxpayers can obtain immunity from penalty and prosecution under the Black Money law.
The Union Budget 2026 has proposed an income-tax exemption for foreign companies supplying capital goods, equipment, or tooling to Indian electronic goods manufacturers operating in customs bonded warehouses under Section 65 of the Customs Act, 1962. At present, Section 11 read with Schedule IV of the Income-tax Act specifies categories of income that are excluded from the total income of eligible non-residents, foreign companies, and specified persons.
Budget 2026-27 Proposes 12-Month Window From Assessment Year End To File Revised Income Tax Returns
As per the proposals in the Union Budget 2026–27, the government has proposed extending the time limit for filing a revised income tax return from the existing nine months to twelve months from the end of the relevant assessment year. At present, the deadlines for filing a belated return under Section 139(4) and a revised return under Section 139(5) coincide, both expiring nine months from the end of the relevant assessment year. As a result, taxpayers who file a belated return towards the end of the permitted period do not get an opportunity to revise their return.
CBDT Issues Draft Income Tax Rules And Forms For New Act With 34% Fewer Rules
The Central Board of Direct Taxes (CBDT) has released the draft Income Tax Rules, 2026 along with the draft forms, in connection with the Income Tax Act, 2025, which is scheduled to come into force from April 1, 2026. The draft rules and forms have been placed in the public domain to invite comments and suggestions from stakeholders and the general public. As per the CBDT, the draft Income Tax Rules, 2026 will remain open for public feedback for a period of 15 days, up to February 22, 2026.
CBDT Issues Draft Income Tax Rules 2026 Navigator Mapping Existing Rules To New Framework
With the Income Tax Act, 2025 set to come into force on 1 April 2026, the Central Board of Direct Taxes (CBDT) has released the Draft Income Tax Rules, 2026 for public consultation. To assist stakeholders in navigating the transition, the CBDT has also published an official navigator that maps each of the 333 draft rules to their corresponding provisions under the existing Income Tax Rules, 1962, which currently comprise 511 rules.
Central Bank Digital Currencies Not 'Relevant Crypto-Assets' For CRS Reporting: CBDT
The Central Board of Direct Taxes (CBDT) has amended the Income Tax Rules, 1962, to clarify that Central Bank Digital Currencies (CBDCs) will not fall within the definition of “relevant crypto-assets” for Common Reporting Standard (CRS) framework. The amendment forms part of the Income-tax (Amendment) Rules, 2026 notified on March 5, 2026 and the changes introduce new definitions and reporting provisions relating to crypto-assets, electronic money products and digital currencies under the Common Reporting Standard (CRS) framework.
CBDT Notifies 2026 Income Tax Rules Introducing 'Tax Year' System, Streamlines Compliance Framework
Today, the Central Board of Direct Taxes (CBDT) notified the Income Tax Rules, 2026, which will come into force from 1 April 2026. The draft rules were published on 9 February 2026 for public consultation, inviting suggestions and feedback. The rules establish the procedural framework for implementing the Income Tax Act, 2025, which repeals the Income-tax Act, 1961.
Finance Minister Nirmala Sitharaman Launches PRARAMBH 2026, Unveils Income Tax Website 2.0
Union Finance Minister Nirmala Sitharaman on Friday (March 20) launched the Income Tax Department's nationwide outreach campaign 'PRARAMBH 2026' in New Delhi and also inaugurated the revamped Income Tax Website 2.0 as part of efforts to prepare taxpayers for the new Income Tax Act, which will come into force from April 1, 2026. The upgraded e-filing portal has been designed to provide improved usability, simpler navigation, and more efficient service delivery to taxpayers as part of the department's ongoing digital transformation initiatives.
The Income Tax Department has clarified that the proposed 12% surcharge in the Finance Bill, 2026 will apply only to the additional income-tax payable by promoters on capital gains arising from buybacks, and not on the entire gains. In a clarification issued on March 26, 2026, the Department explained that the amendment relates to taxation of capital gains earned by promoters when companies buy back their own shares under section 68 of the Companies Act, 2013, which governs share buybacks.