SUPREME COURT
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.
HIGH COURTS
Delhi HC
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.
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.
ITAT
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.”
OTHER DEVELOPMENTS
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.