SUPREME 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.
HIGH COURTS
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.
Calcutta HC
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 : 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.
Gujarat HC
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.
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.
Orissa HC
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.
ITAT
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.