LiveLawBiz Direct Tax Weekly Round-Up: April 06 - April 12, 2026

Update: 2026-04-14 05:00 GMT

HIGH COURTS

Andhra Pradesh HC

TEP-Based Income Tax Summons Can't Be Quashed Without Proof Of Mala Fide: Andhra Pradesh High Court

Case Title : Koduru Picheswara Rao v. Union of India

Case Number : WRIT PETITION No. 841 of 2026

CITATION : 2026 LLBiz HC(APH) 28

The Andhra Pradesh High Court has held that summons issued under Section 131(1A) of the Income Tax Act on the basis of a Tax Evasion Petition (TEP) cannot be quashed in writ jurisdiction in the absence of clear and convincing proof of mala fide, particularly where such allegations are raised belatedly and lack foundational pleadings or supporting material. A Division Bench of Justice Ravi Nath Tilhari and Justice Balaji Medamalli dismissed a writ petition filed by Koduru Picheswara Rao challenging summons issued by the Income Tax Department. The judges observed: In VNG Automotive Case “the impugned notice/summons under Section 131 (1A) of the Income Tax Act cannot be said to be illegal or suffering from any infirmity, neither on the ground of malice nor on the ground of jurisdictional error.”

Madras HC

Madras High Court Quashes IT Case Against Gautham Vasudev Menon Over Non-Filing Of His Company's Returns

Case Title : Gautham Vasudev Menon v. The Asst Commissioner of Income Tax and Others

Case Number : Crl OP 8726 of 2023

The Madras High Court on Monday quashed an income tax prosecution against filmmaker Gautham Vasudev Menon for failure to file the income tax returns of his company, Photon Kathaas Productions Pvt Ltd, for the assessment year 2013-14. Justice GK Ilanthiraiyan quashed the case pending against Menon before the Additional Chief Metropolitan Magistrate. The case against Menon was initiated under Section 276 CC read with Section 278B of the Income Tax Act for non-filing of the returns of the company for the assessment year 2013-14.

ITAT

ITAT Ahmedabad Condones 153-Day Delay By Senior Citizen Unaware Of Tax Procedure, Orders Fresh Hearing

Case Title : Meenaben Vishnubhai Patel v. The ITO

Case Number : ITA No.395/Ahd/2026

CITATION : 2026 LLBiz ITAT(AHM) 86

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 23 March, held that delay in filing an appeal by a lady senior citizen constituted a sufficient and reasonable cause, and restored the matter for fresh adjudication. A Bench comprising Judicial Member Suchitra Kamble and Accountant Member Annapurna Gupta condoned a delay of 153 days, observing that the taxpayer's unfamiliarity with income tax procedures and technology justified the delay.

Reassessment Based On General Penny Stock Reports Alone Cannot Stand: ITAT Ahmedabad

Case Title : Bhupesh Sajjansinh Rathod v. NFAC, Delhi

Case Number : ITA No. 1800/Ahd/2025

CITATION : 2026 LLBiz ITAT(AHM) 87

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 1 April, held that reassessment cannot be based solely on general penny stock investigation reports without any material linking the taxpayer, and deleted additions made towards alleged bogus capital gains and commission. The Bench comprising Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta allowed the appeal of Bhupesh Sajjansinh Rathod, an individual investor, against the order of the Commissioner of Income Tax (Appeals), NFAC, which had upheld additions arising from alleged penny stock transactions.

Unspent Accumulation Taxable After 5 Years For Charitable Trusts: ITAT Ahmedabad

Case Title : Deputy Commissioner of Income Tax (Exemptions) v. State Examination Board

Case Number : ITA No. 1505/Ahd/2025

CITATION : 2026 LLBiz ITAT(AHM) 88

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 1 April held that income accumulated by a charitable entity but not utilised within the permitted five-year period becomes taxable, and claiming exemption again on such amount amounts to double deduction. A Bench comprising Judicial Member Sanjay Garg and Accountant Member Annapurna Gupta, allowed the Revenue's appeal and restored the addition made by the Assessing Officer against State Examination Board, Nr. Government Library.

Persistent Loss Should Be Continuous Over 3 Years: ITAT Delhi Orders Rework Of TP Addition For Keysight

Case Title : Keysight Technologies International India Pvt. Ltd. v. The Dy. CIT

Case Number : ITA No.3813/Del/2024

CITATION : 2026 LLBiz ITAT(DEL) 89

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has partly allowed the taxpayer's appeal, holding that companies cannot be excluded as comparables merely for incurring losses in two out of three years and that foreign exchange fluctuations arising from business transactions must be treated as operating in nature. A coram comprising Judicial Member Yogesh Kumar U.S. and Accountant Member Manish Agarwal held that “persistent loss filter can be applied only if there is loss in three successive assessment years and if there is profit in anyone of the three successive financial years selected, then the company cannot be excluded,” while dealing with the exclusion of certain comparables by the Transfer Pricing Officer (TPO).

ITAT Kolkata Remands ₹92.67 Crore Addition Against Addhya Forex, Upholds Right To Fair Hearing

Case Title : Addhya Forex (P) Ltd. v. ITO, Ward-8(1), Kolkata

Case Number : ITA No. 215/KOL/2025

CITATION : 2026 LLBiz ITAT(KOL) 91

The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) on 6 April remanded reassessment proceedings against Addhya Forex (P) Ltd., holding that the addition of Rs. 92.67 crore was based on ex parte orders and directing the Assessing Officer to give the taxpayer a fresh opportunity to present its case. A Bench comprising Judicial Member George Mathan and Accountant Member Rakesh Mishra set aside the order of the Commissioner of Income Tax (Appeals), observing: In VNG Automotive Case “Since no compliance was made before the Ld. AO as well as before the Ld. CIT(A) and both the orders are in effect ex parte orders, therefore, in the interest of justice and fair play it was considered that the request of the assessee to set aside the case before the Ld. AO may be allowed.”

ITAT Kolkata Deletes ₹43.98 Lakh Addition Against Disha Eye Hospitals For Genuine SBN Receipts

Case Title : Disha Eye Hospitals Pvt. Ltd. v. DCIT, Circle-14(1), Kolkata

Case Number : ITA No. 2420/KOL/2025

CITATION : 2026 LLBiz ITAT(KOL) 90

The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) on 6 April deleted a Rs. 43.98 lakh addition made against Disha Eye Hospitals Pvt. Ltd., holding that receipts from a genuine source, even if in demonetised notes (SBNs), cannot be treated as unexplained money under Section 69A of the Income Tax Act. A Bench comprising Judicial Member George Mathan and Accountant Member Rakesh Mishra observed: In VNG Automotive Case “Only on account of the fact that the receipts were in SBNs, the same could not be added u/s 69A of the Act when the source of receipts has not been disputed.”

ITAT Kolkata Remands DIC Fine Chemicals' Transfer Pricing, Book Profit, Interest Adjustments Per APA

Case Title : M/s DIC Fine Chemicals Pvt. Ltd. v. DCIT, Circle-11(1), Kolkata

Case Number : ITA No. 2611/KOL/2024

CITATION : 2026 LLBiz ITAT(KOL) 92

The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) on 6 April, held that when a company enters into an Advance Pricing Agreement (APA) with the Central Board of Direct Taxes (CBDT) covering the relevant assessment year, transfer pricing disputes must be reconsidered in accordance with the APA. A Bench of Judicial Member Sonjoy Sarma and Accountant Member Rakesh Mishra remanded the arm's length price determination for AY 2021-22 in favour of DIC Fine Chemicals, observing that the APA dated 24 March 2025 applies to this year and must guide the adjustments. The Tribunal held: In VNG Automotive Case “Since the assessee had entered into an APA with the CBDT and the impugned AY 2021-22 is also covered in the APA dated 24.03.2025, the issue of Arm's Length Price... is hereby remanded to the Ld. AO who shall consider the APA and thereafter make an adjustment as per law.”



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