SUPREME COURT
Case Title : ASSISTANT COMMISSIONER OF INCOME TAX Versus M/S ATLANTIC GLOBAL SHIPPING PVT. LTD.
Case Number : Diary No. 25162-2026
The Supreme Court on Wednesday issued notice in the Income Tax Department's appeal challenging a Gujarat High Court judgment that held ST Shipping Pte Ltd, Singapore was entitled to the benefit of Article 8 of the India-Singapore Double Taxation Avoidance Agreement (DTAA). Under Article 8 of the DTAA, profits from the operation of ships in international traffic are taxable only in the country of residence. A bench of Justices P.S. Narasimha and Alok Aradhe while issuing notice on the Revenue's appeal said that it would assign a date for hearing the matter.
HIGH COURTS
Bombay HC
Bombay High Court Sets Aside Order Rejecting Naresh Goyal's Objections In Income Tax Reassessment
Case Title : Naresh Jagdishrai Goyal vs Deputy Commissioner of Income-tax Central Circle 5(2), Mumbai and Ors.
Case Number : WRIT PETITION NO. 3073 OF 2022
CITATION : 2026 LLBiz HC(BOM) 393
The Bombay High Court has recently set aside an order rejecting former Jet Airways chairman Naresh Goyal's objections to the reopening of his income tax assessment for the Assessment Year 2014-15. It directed the Assessing Officer to reconsider the objections after taking into account Goyal's March 8, 2022 letter and the annexures explaining the source of funds used to acquire Jet Airways (India) Ltd. shares.
Bombay High Court Says ITAT Took 'Pedantic Approach', Condones 1,797-Day Delay in Income Tax Appeals
Case Title : Uttar Bhartiya Education Society v. Principal Commissioner of Income Tax (Exemption) & Ors.
Case Number : Income Tax Appeal (L) Nos. 20375 of 2026 and 20379 of 2026
CITATION : 2026 LLBiz HC(BOM) 395
The Bombay High Court has set aside an Income Tax Appellate Tribunal (ITAT) order refusing to condone a 1,797-day delay in appeals filed by Uttar Bhartiya Education Society. Holding that the trust's explanation for the delay deserved due consideration, the court condoned the delay and restored the appeals for a decision on merits. A division bench of Justice G.S. Kulkarni and Justice Aarti Sathe held that the tribunal had adopted a "pedantic approach" while rejecting the charitable trust's plea for condonation of delay. It found that the trust had explained the reasons for the delay before both the Commissioner of Income Tax (Appeals) and the ITAT.
Case Title : Shreenath Finstock Private Ltd. v. Union of India & Ors.
Case Number : Writ Petition No. 3526 of 2022
CITATION : 2026 LLBiz HC(BOM) 396
The Bombay High Court has held that an income tax reassessment notice dated and digitally signed on March 31, 2021, cannot be treated as having been issued on that date if it was actually dispatched through the Income Tax Business Application (ITBA) portal and reached the assessee only on April 1, 2021. The court ruled that the notice would be deemed to have been issued on April 1, 2021, and the reassessment proceedings must continue under the framework introduced by the Finance Act, 2021.
Delhi HC
Delhi High Court Quashes ₹21 Crore Block Assessment Over Failure To Issue Mandatory Scrutiny Notice
Case Title : Sun Aero Ltd v. Principal Commissioner Of Income Tax
Case Number : ITA 527/2017
CITATION : 2026 LLBiz HC (DEL) 697
The Delhi High Court has reiterated that issuance of a notice under Section 143(2) of the Income Tax Act, 1961, is mandatory for completing block assessments under Section 158BC of the Act. A Division Bench of Justices Dinesh Mehta and Rajneesh Kumar Gupta relied on Assistant Commissioner of Income Tax vs. Hotel Blue Moon (2010), where the Supreme Court held that the omission to issue such notice is not a curable procedural irregularity.
Karnataka HC
Case Title : Principal Commissioner of Income Tax v. Unisys India Pvt. Ltd. c/w Principal Commissioner of Income Tax v. H.K. Suresh
Case Number : ITA No. 55 of 2024 c/w ITA No. 216 of 2023
CITATION : 2026 LLBiz HC(KAR) 117
The Karnataka High Court has held that an income tax order initially communicated without a Document Identification Number (DIN) does not become invalid merely because the DIN is communicated later through a separate authenticated intimation letter. The court held that the procedure substantially complied with CBDT Circular No. 19/2019 as it maintained the audit trail and authenticity of departmental communications. A Division Bench of Justice S.G. Pandit and Justice K.V. Aravind allowed two appeals filed by the Revenue against orders of the Income Tax Appellate Tribunal (ITAT), Bengaluru.
Karnataka High Court Holds S. 271DA Penalty Begins Only With S. 274 Notice, Reads In Six Month Limit
Case Title : Joint Commissioner of Income Tax & Anr. v. Ganesh Agarwal & Connected Matters
Case Number : WA No. 1991 of 2025 c/w WA Nos. 1977, 1980, 1982, 1994, 1995, 1996, 2003, 2021 & 2023 of 2025
CITATION : 2026 LLBiz HC(KAR) 118
The Karnataka High Court on 7 July held that penalty proceedings under Section 271DA of the Income Tax Act commence only when the Joint Commissioner issues a show cause notice under Section 274, and not when the Assessing Officer merely forwards a proposal for initiating penalty. A Division Bench of Justices S.G. Pandit and K.V. Aravind partly allowed a batch of ten Revenue appeals, clarifying that, although the Act does not prescribe a time limit for issuing a notice under Section 274, the Joint Commissioner must issue it within six months from the end of the month in which the proposal is received from the Assessing Officer.
Case Title : Pr. Commissioner of Income Tax v. Shri Ravi Shankar Shetty
Case Number : INCOME TAX APPEAL NO. 225 OF 2021
CITATION : 2026 LLBiz HC(KAR) 122
The Karnataka High Court has upheld the deletion of a ₹21.11 crore tax addition made against a Bengaluru-based businessman engaged in identifying and procuring land for real estate projects. The court held that advances received in the course of that business cannot be taxed merely because they remained outstanding for several years. The court observed that the mere passage of time does not amount to forfeiture, and such advances cannot be treated as taxable income in the absence of material showing that the recipient had become absolutely entitled to retain the money.
Madras HC
Madras High Court Grants Stay On ₹101.14 Crore TDS Penalty Recovery Against Cognizant
Case Title : Cognizant Technology Solutions v. Assistant Commissioner of Income Tax
Case Number : WP Nos.25670/2026
CITATION : 2026 LLBiz HC(MAD) 178
The Madras High Court on 6 July granted interim relief to Cognizant Technology Solutions India Private Limited by staying recovery proceedings arising from tax deducted at source (TDS) penalty demands exceeding Rs. 101.14 crore. A Bench of Justice Senthilkumar Ramamoorthy found that the company had established a prima facie case, directed it to deposit Rs. 4 crore within two months, and stayed recovery of the balance penalty amount until the Commissioner of Income Tax (Appeals) decides the pending appeals and for two weeks thereafter.
Telangana HC
Case Title : DBS Technology Services India Private Limited v. Assistant Commissioner of Income Tax
Case Number : WRIT PETITION NO.19502 OF 2025
CITATION : 2026 LLBiz HC (TEL) 46
The Telangana High Court on 3 July held that the Income Tax Department cannot reject a genuine claim for deduction on the sole ground of a technical or procedural lapse if the taxpayer is otherwise entitled to the benefit. A Division Bench of Justices P. Sam Koshy and Suddala Chalapathi Rao set aside the order rejecting the deduction claimed by DBS Technology Services India Private Limited and directed the Assessing Officer to reconsider the company's claim in accordance with law.
Telangana High Court Upholds Capital Gains Tax Exemption Despite Delay In Villa Registration
Case Title : Sudhakar Reddy Mettu v. Assistant Commissioner of Income Tax
Case Number : INCOME TAX TRIBUNAL APPEAL No.78 of 2025
CITATION : 2026 LLBiz HC (TEL) 52
The Telangana High Court has held that a taxpayer who invested capital gains in a residential villa under a joint development agreement cannot be denied tax exemption merely because the developer delayed construction and execution of the sale deed. The court observed that delays beyond the assessee's control cannot defeat the benefit intended under the law. A Division Bench of Justice P. Sam Koshy and Justice Narsing Rao Nandikonda allowed the appeal filed by non-resident Indian Sudhakar Reddy Mettu. It set aside the Income Tax Appellate Tribunal's order denying him the exemption.
ITAT
Case Title : National Lubricating Grease Institute India Chapter v. CIT (Exemption), Chandigarh
Case Number : ITA No. 8271/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 242
The New Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 10 July held that an institution does not lose its charitable character merely because its activities benefit a specific industry, and set aside the Commissioner (Exemptions)'s order rejecting registration of the National Lubricating Grease Institute India Chapter under Sections 12AA/12AB of the Income Tax Act. A Bench comprising Accountant Member S. Rifaur Rahman and Judicial Member Vimal Kumar held: “Only because of specific group of participants of lubricating grease industry are directly benefitted cannot be a ground to question the charitable nature of a Society.”
Case Title : KBC Bank Naamloze Vennootschap v. Assistant Commissioner of Income Tax, International Tax Circle 3(1)(2), Mumbai
Case Number : ITA No. 8160/Mum/2025
CITATION : 2026 LLBiz ITAT(MUM) 243
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has remanded to the Assessing Officer (AO) the issue of taxability of a ₹3.14 crore write-back of general provision for standard assets, observing that if the assessee had already accounted for the amount in its profit and loss account and neutralised its effect while computing taxable income, it could not be brought to tax again. A bench of Judicial Member Beena Pillai and Accountant Member Arun Khodpia partly allowed the appeal filed by KBC Bank Naamloze Vennootschap for statistical purposes.
Carbon Credit Sale Receipts Are Capital Gains, Not Taxable Before AY 2017-18 : ITAT New Delhi
Case Title : Jindal Saw Ltd. (formerly Saw Pipes Ltd.) v. Deputy Commissioner of Income Tax
Case Number : ITA Nos. 2383 & 2384/Del/2018, 2747 & 2748/Del/2018 and 463/Del/2019
CITATION : 2026 LLBiz ITAT(DEL) 244
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 13 July held that receipts from the sale of carbon credits are capital receipts and are not taxable for Assessment Years 2012-13 and 2013-14. Judicial Member Satbeer Singh Godara and Accountant Member Manish Agarwal dismissed the Revenue's appeals and partly allowed the appeals filed by Jindal Saw Ltd. (formerly known as Saw Pipes Ltd.). The Bench observed: “We conclude in this factual backdrop that the assessee's impugned identical receipt(s) derived from sale/transfer of carbon credits is not taxable being capital in nature which also deserve to be excluded for section 115JB MAT computation in very terms.”
Case Title : DCIT (International Taxation)-4(2)(2) v. Standard Chartered Bank & Standard Chartered Bank v. DCIT (International Taxation)-4(2)(2)
Case Number : ITA Nos. 4247 & 4275/Mum/2025 and ITA Nos. 4264 & 4265/Mum/2025
CITATION : 2026 LLBiz ITAT(MUM) 245
Salary paid by the head office of a foreign bank to expatriate employees working exclusively for its Indian operations cannot be treated as head office expenditure merely because the payment was initially made outside India, the Mumbai Income Tax Appellate Tribunal (ITAT) has held. A bench of Judicial Member Beena Pillai and Accountant Member Arun Khodpia dismissed the Revenue's appeal. It upheld the Commissioner (Appeals)' order allowing Standard Chartered Bank's claim for deduction of expatriate salary expenditure.
Other Developments
CBDT Notifies No TDS on Specified Payments to Eligible IFSC Units Under Income-tax Act, 2025
The Central Board of Direct Taxes (CBDT) has exempted specified payments made to eligible units operating in an International Financial Services Centre (IFSC) from tax deduction at source (TDS), provided the units have opted to claim deductions under the Income-tax Act, 2025. The exemption is available only for the categories of payments notified by the government and is subject to prescribed conditions.
Centre Notifies Oman's Social Protection Fund For Tax Exemption On Eligible Investments In India
The central government has notified Oman's Social Protection Fund (SPF) as a specified person eligible to claim tax exemption on qualifying investments made in India under the Income Tax Act, 2025. This will apply to eligible investments made from the date of publication of the notification in the Official Gazette until March 31, 2030, subject to prescribed conditions. The notification, issued by the Central Board of Direct Taxes (CBDT), requires the fund to file income tax returns within the prescribed timelines along with a compliance certificate from an accountant. It must also disclose details of its investments in India every quarter.