HIGH COURTS
Kerala HC
Kerala HC Directs CIT To Reconsider Registration Of Trust From 2021, Examines CBDT Circular 7/2024
Case Title : Atma Bodhodaya Sangham Sree Subhananda Trust v. Commissioner of Income Tax (Exemptions)
Case Number : ITA No. 120 of 2025
CITATION : 2026 LLBiz HC(KER) 93
On 4 June, the Kerala High Court directed the Commissioner of Income Tax (Exemptions) to reconsider a Atma Bodhodaya Sangham Sree Subhananda Trust's claim for registration under Section 12A of the Income Tax Act with effect from 1 April 2021, after examining the applicability of CBDT Circular No. 7/2024 on rectification of defective exemption applications. A Division Bench of Justices Devan Ramachandran and Basant Balaji set aside the orders of the Income Tax Appellate Tribunal (ITAT) and the Commissioner of Income Tax (Exemptions), which had denied retrospective registration to the Trust, and remitted the matter for fresh consideration with a direction to complete the exercise within three months.
ITAT
Case Title : FireEye Ireland Limited v. ACIT
Case Number : ITA Nos. 825/Del/2023 and 3701/Del/2023
CITATION : 2026 LLBiz ITAT(DEL) 165
On 5 June, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) held that consideration received from the sale of standard cybersecurity software licences, subscriptions, and related support services does not qualify as Fees for Technical Services (FTS), as FireEye Ireland Limited did not render any customised technical or consultancy services. Judicial Member Vikas Awasthy and Accountant Member Renu Jauhari partly allowed the appeals filed by FireEye Ireland Limited for Assessment Years 2020–21 and 2021–22.
ITAT Delhi Quashes Antriksh Group Assessments Over Mechanical Search Assessment Approval
Case Title : Antriksh Engineers Construction Corporation & Ors. v. ACIT
Case Number : ITA Nos. 8842 to 8846, 8851 to 8855, 8847 to 8850, 8856 to 8862 and 8911 & 8912/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 166
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has recently reiterated that approval required before search assessments are finalised must reflect independent application of mind and cannot be accorded mechanically through a common approval covering multiple assessees and assessment years. Holding that the approval granted in the present case suffered from non-application of mind, the Tribunal quashed assessments framed against various entities and individuals belonging to the Antriksh group.
Section 68 Addition Unsustainable Where Identity and Creditworthiness Are Proven: ITAT New Delhi
Case Title : DCIT v. ANR International Pvt. Ltd.
Case Number : ITA No. 5317/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 167
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 5 June held that an addition under Section 68 of the Income Tax Act cannot be sustained merely because share subscribers disclosed relatively low income in their income tax returns, where the taxpayer establishes their identity, creditworthiness, and the genuineness of the transactions. Judicial Member Raj Kumar Chauhan and Accountant Member Renu Jauhari dismissed the Revenue's appeal and upheld the Commissioner (Appeals)' decision deleting a Rs. 3 crore addition made against ANR International Pvt. Ltd. for Assessment Year 2017-18.
Case Title : Ramatas Revathi v. The Income Tax Officer
Case Number : ITA No 4128/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 168
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) has held that a taxpayer cannot be denied the benefit of indexation on the cost of construction where details relating to the building are already available in the registered sale deed and form part of the material on record. A coram of Judicial Member Manu Kumar Giri and Accountant Member Gagan Goyal allowed an appeal filed by Ramatas Revathi.
Case Title : DCIT v. Excel Insurance Outsourcing Pvt. Ltd.
Case Number : ITA Nos. 1355 & 1356/Del/2026
CITATION : 2026 LLBiz ITAT(DEL) 169
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has held that, in the case of a person who was not subjected to a search, the relevant assessment block must be computed with reference to the date on which the jurisdictional Assessing Officer records satisfaction after receiving the seized material and not with reference to the date of the search conducted on a third party. A bench of Judicial Member Sudhir Kumar and Accountant Member Naveen Chandra dismissed two appeals filed by the Revenue and affirmed the order of the Commissioner of Income Tax (Appeals), which had quashed assessments against Excel Insurance Outsourcing Pvt. Ltd. for Assessment Years 2010-11 and 2011-12.
Case Title : Straumann Dental India LLP v. ACIT
Case Number : ITA No. 8894/Del/2025
CITATION : 2026 LLBiz ITAT(DEL) 170
On 10 June, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) held that depreciation cannot be claimed on goodwill arising from an unsigned and unregistered business transfer agreement. Judicial Member Madhumita Roy and Accountant Member Amitabh Shukla dismissed the appeal filed by Straumann Dental India LLP for Assessment Year 2017-18 and upheld the disallowance of depreciation of Rs 16.16 crore claimed on goodwill.
Case Title : Arvind Mevalal Panchal v. Income Tax Officer
Case Number : ITA No. 2203/AHD/2025
CITATION : 2026 LLBiz ITAT(AHM) 171
The Income Tax Appellate Tribunal (ITAT) in Ahmedabad has held that a taxpayer who was aware of ongoing appellate proceedings cannot avoid the consequences of earlier non-compliance merely because the final notice was sent to a different email address. A division bench of Judicial Member T.R. Senthil Kumar and Accountant Member Narendra Prasad Sinha made the observation while allowing an appeal filed by Arvind Mevalal Panchal for statistical purposes against an order of the National Faceless Appeal Centre (NFAC) for the assessment year 2018-19.
Case Title : Assistant Commissioner of Income Tax, Circle v. Gulbrandsen Pvt. Ltd.
Case Number : ITA Nos. 2281 & 2282/AHD/2025
CITATION : 2026 LLBiz ITAT(AHM) 172
The Income Tax Appellate Tribunal (ITAT) has held that non-production of bills and vouchers could not be a valid reason to deny additional depreciation where the tax department had accepted the asset as plant and machinery and allowed normal depreciation on it. A division bench of Judicial Member T.R. Senthil Kumar and Accountant Member Narendra Prasad Sinha upheld the relief granted to Gulbrandsen Private Limited while deciding the Revenue's appeals for Assessment Years 2012-13 and 2013-14.
Case Title : EBIXCASH World Money Limited v. DCIT, Circle-2(1)(1)
Case Number : ITA No. 8607/MUM/2025
CITATION : 2026 LLBiz ITAT(MUM) 173
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has deleted a transfer pricing adjustment of ₹76.45 crore made on interest paid by EBIXCASH World Money Limited on compulsorily convertible debentures (CCDs). The tribunal held that precedents consistently recognise CCDs as debt instruments and that interest paid on them cannot be disallowed by treating them as equity. “We find that the grounds of appeal raised by assessee is in fact covered by a series of decisions of Tribunal and High Courts wherein it is consistently held that CCDs cannot be treated as equity and interest in respect of CCD cannot be disallowed by TPO,” the tribunal observed.
SBI Not In Default For Not Deducting Tax On Leave Travel Claims Under HC Directions: ITAT Ahmedabad
Case Title : State Bank of India v. Income Tax Officer & Anr.
Case Number : ITA Nos. 1338, 1339, 1392 and 1498/AHD/2026
CITATION : 2026 LLBiz ITAT(AHM) 174
The Ahmedabad Bench of the Income Tax Appellate Tribunal on Friday held that the State Bank of India could not be treated as an assessee in default for failing to deduct tax at source on Leave Fare Concession payments made to employees. The tribunal found that the bank had acted in accordance with binding interim directions of the Madras High Court. A bench of Vice President Dr. B.R.R. Kumar and Judicial Member Rahul Chaudhary allowed four appeals filed by different SBI branches.
Following Earlier Rulings, ITAT Mumbai Allows DSIR-Unapproved R&D Expenditure As Business Deduction
Case Title : Manugraph India Limited v. ACIT Circle – 3(2)(1), Mumbai
Case Number : ITA No. 7160/MUM/2025
CITATION : 2026 LLBiz ITAT(MUM) 175
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has allowed Manugraph India Limited to claim ₹22 lakh in research and development (R&D) expenditure as a business deduction. The amount had not been approved by the Department of Scientific and Industrial Research (DSIR) for weighted deduction. The tribunal followed earlier decisions that permitted such claims under the Income Tax Act.
Case Title : Rakesh Kumar v. ITO, Ward 58 (6)
Case Number : ITANo.5882/DEL/2025
CITATION : 2026 LLBiz ITAT(DEL) 176
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has deleted a ₹5.60 crore addition made against a Delhi jeweller over cash deposits during the demonetisation period. The bench found that the source of the deposits was recorded in the taxpayer's audited books of account and that the related business income had already been assessed. The bench comprising Vice President Mahavir Singh and Accountant Member S. Rifaur Rahman allowed the appeal filed by Rakesh Kumar, proprietor of R.V. Gold Hallmark.