LiveLawBiz Direct Tax Weekly Round-Up: March 30 - April 05, 2026
Kapil Dhyani
7 April 2026 2:17 PM IST
SUPREME COURT
Case Title : Deputy Commissioner of Income Tax v. Reliance Industries Limited
Case Number : Diary No(s). 4339/2026
CITATION : 2026 LLBiz SC 141
The Supreme Court on Wednesday refused to interfere with a Bombay High Court ruling that had quashed income tax assessments issued in the names of Reliance Polyethylene Ltd. and Reliance Polypropylene Ltd. even after their merger with Reliance Industries Ltd., noting that the Revenue has issued a fresh notice pursuant to the High Court's decision. A Bench of Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe dismissed the Revenue's special leave petitions after recording that the Revenue has issued fresh notice.
Case Title : Deputy Commissioner of Income Tax vs RRPR Holdings Pvt Ltd
Case Number : SPECIAL LEAVE PETITION (CIVIL) Diary No(s). 74314/2025
CITATION : 2026 LLBiz SC 143
The Supreme Court on Thursday dismissed special leave petitions filed by the Income Tax Department against RRPR Holdings Pvt Ltd, the promoter holding company of NDTV, on the ground of a delay of 372 days, declining to condone the inordinate delay and leaving undisturbed the Delhi High Court's ruling quashing reassessment proceedings. Holding that no bona fide or plausible explanation had been furnished by the department, a bench of Justices Pamidighantam Sri Narasimha and Alok Aradhe observed: “There is a delay of 372 days in filing these Special Leave Petitions and we do not find any bonafide and plausible explanation to condone this inordinate delay. The Special Leave Petitions are, accordingly, dismissed on the ground of delay.”
HIGH COURTS
Bombay HC
Case Title : Benteler Automotive (China) Investment Ltd. v. ACIT & Ors.
Case Number : Writ Petition No. 11074 of 2025
CITATION : 2026 LLBiz HC(BOM) 172
The Bombay High Court has refused to grant a nil withholding tax certificate under Section 197 to a China-based company, holding that services delivered through emails and video conferencing can be treated as rendered in India, while also declining to interfere as the core tax dispute is pending before appellate authorities. A bench of Justices B. P. Colabawalla and Amit S. Jamsandekar observed that “the rendition of these services, even if done virtually, equate to and is the same as a physical rendition of services in India. Hence, even assuming for the sake of argument that physical presence is required in India as sought to be contended by the Petitioner, the same is duly fulfilled."
Delhi HC
Case Title : Huawei Telecommunications (India) Company Pvt. Ltd. v. Assistant Commissioner Of Income Tax, Central Circle-2, Delhi & Anr
Case Number : W.P.(C) 15970/2023
CITATION : 2026 LLBiz HC (DEL) 316
The Delhi High Court has granted partial relief to Huawei Telecommunications (India) in a batch of petitions challenging special audit directions and reassessment proceedings initiated by the Income Tax Department. A Division Bench of Justices V. Kameswar Rao and Vinod Kumar partly allowed the petitions, setting aside the special audit directions and reassessment notices for Assessment Year (AY) 2013-14, while sustaining the proceedings for AY 2015-16.
Case Title : Delhi Sports And Entertainment Private Limited v. Deputy Commissioner Of Income Tax & Ors.
Case Number : W.P.(C) 3152/2026
CITATION : 2026 LLBiz HC (DEL) 317
The Delhi High Court has quashed reassessment proceedings against a Delhi-based sports events company, holding that the notice issued on July 30, 2022 was time-barred and that reopening the case on issues already scrutinized amounted to a mere change of opinion, rendering the entire exercise invalid. A Division Bench of Justices Dinesh Mehta and Vinod Kumar allowed the writ petition filed by the company, setting aside the reassessment notice, subsequent orders, and the ex-parte assessment order raising a demand of over Rs. 96 crore.
Case Title : APS Hydro Private Limited v. Union of India & Ors.
Case Number : W.P.(C) 9132/2022
CITATION : 2026 LLBiz HC (DEL) 336
The Delhi High Court has recently pulled up the Income Tax Department for waking up after nine years to pursue tax dues, calling it “difficult nay impossible” to believe such prolonged inaction, and quashed the notice issued to APS Hydro Private Limited. A division bench of Justice Dinesh Mehta and Justice Vinod Kumar was dealing with a writ petition against a notice dated February 16, 2022, and a follow-up communication issued on May 12, 2022, by the Assistant Commissioner of Income Tax, which treated the taxpayer as being in default under the Income Tax Act.
Gujarat HC
Case Title : Purvibhavin Shah v. The Income Tax Officer
Case Number : R/SPECIAL CIVIL APPLICATION NO. 3845 of 2026
CITATION : 2026 LLBiz HC(GUJ) 48
The Gujarat High Court has recently held that while computing the extended ten-year period for reopening income tax assessments following a search, the assessment year in which the search was conducted must be included in the reckoning. The bench stated that "..... the assessment year relevant to the previous year of search becomes the reference year and the ten-year period is counted from the end of that assessment year. This necessarily includes the search assessment year within the ten-year framework and resultantly, the search year becomes the first year in the reckoning of the ten-year block."
Karnataka HC
Case Title : United Spirits Limited v. Deputy Commissioner of Income Tax
Case Number : WRIT PETITION No.18439 OF 2024
CITATION : 2026 LLBiz HC (KAR) 45
Rejecting the income tax department's attempt to treat a Tribunal remand as a fresh transfer pricing reference to extend limitation, the Karnataka High Court has held that no order can be passed once the statutory time limit expires. A single-judge bench of Justice Nagaprasanna emphasised that there is a “world of difference” between a reference made by the Assessing Officer to the Transfer Pricing Officer under Section 92CA(1) and a remand of the matter by the Tribunal, rejecting the Revenue's attempt to treat both as triggering a fresh limitation period.
Kerala HC
Madras HC
ITAT
ITAT Delhi Dismisses Multiple Revenue Appeals Against Make My Trip Across TP, TDS Issues
Case Title : DCIT, New Delhi vs. M/s. Make My Trip India Pvt. Ltd.
Case Number : ITA No.5095/Del/2014
CITATION : 2026 LLBiz ITAT(AHM) 79
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has dismissed a batch of appeals filed by the Revenue against MakeMyTrip India Pvt. Ltd. It held that advertisement, marketing, and promotion (AMP) expenditure cannot be treated as an international transaction where the Indian entity owns the brand and upheld deletion of a Rs. 31.81 crore transfer pricing adjustment. The bench comprising Judicial Member C.N. Prasad and Accountant Member M. Balaganesh was dealing with appeals arising from orders of the Commissioner of Income Tax (Appeals). The matters related to assessment years 2009–10, 2011–12, and 2012–13 to 2015–16.
Overall Assessment Time Limit Applies Even In Dispute Resolution Panel Cases: ITAT New Delhi
Case Title : BT India Pvt. Ltd. v. ACIT, Circle-4(2), Delhi
Case Number : ITA Nos. 533 & 1701/Del/2022 (ITAT Delhi)
CITATION : 2026 LLBiz ITAT(DEL) 79
The Delhi Bench of the Income Tax Appellate Tribunal has ruled that final assessment orders under Section 144C (DRP route) must comply with the overarching time limit under Section 153 (assessment deadline), holding that orders passed beyond this limit are time-barred. A coram comprising Judicial Member Vikas Awasthy and Accountant Member Sanjay Awasthy was dealing with appeals filed by BT India Pvt. Ltd. for Assessment Years 2017-18 and 2018-19, wherein the primary issue was whether the assessment orders were barred by limitation.
Reassessment Beyond Three Years Without PCCIT Approval Invalid: ITAT Chennai
Case Title : Vasanthi Ragunathan v. The ITO Ward
Case Number : ITA No.2896/Chny/2025
CITATION : 2026 LLBiz ITAT(CHE) 80
The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) on 25 March held that reassessment proceedings initiated beyond three years from the end of the relevant assessment year are invalid if the Assessing Officer does not obtain prior approval from the Principal Chief Commissioner of Income Tax (PCCIT), as mandated under the Income Tax Act. The Bench, comprising Judicial Member Aby T. Varkey and Accountant Member S.R. Raghunatha, set aside the reassessment notice issued against Vasanthi Ragunathan, observing: “the notice under section 148 is dated 13.04.2022, which event is undisputedly beyond the period of 3 years from the end of the relevant AY; and therefore as per the provisions of Section 151 of the Act, the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT) before issuing the ibid notice. However, in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT), Coimbatore, while issuing notice under section 148 and therefore the notice is found to be in defiance to prescription given in section 151 of the Act and hence it is invalid in eyes of law.”
Disallowance Irrelevant Where Tax Liability Arises Under MAT: ITAT Ahmedabad
Case Title : Shalby Ltd. v. Principal Commissioner of Income Tax
Case Number : ITA No. 1227/AHD/2025
CITATION : 2026 LLBiz ITAT(AHM) 81
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) on 26 March, reiterated that a disallowance computed under Rule 8D of the Income Tax Rules cannot be imported into the computation of book profit under the Minimum Alternate Tax (MAT) provisions. The Bench, comprising Judicial Member Suchitra Kamble and Accountant Member Narendra Prasad Sinha, allowed the appeal filed by Shalby Ltd., observing that even if the alleged disallowance were made, it would not impact the taxpayer's liability, as the tax for the relevant assessment year arose entirely under the MAT provisions.
No TDS Under Section 194-IA On Rural Agricultural Land Transactions: ITAT Ahmedabad
Case Title : The Income Tax Officer v. Tarun Santramdas Varma
Case Number : I.T.A. No.2549/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 82
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) 26 March, held that buyers of rural agricultural land are not required to deduct TDS under Section 194-IA of the Income Tax Act, and interest under Section 201(1A) is not leviable. The Bench, comprising Vice-President Dr. B.R.R. Kumar and Judicial Member Suchitra Kamble, dismissed the Revenue's appeal while confirming that Tarun Santramdas Varma (taxpayer) did not owe TDS on certain rural agricultural land transactions.
Case Title : Firoj Sabbirmohmmad Moravala v. Income Tax Officer
Case Number : ITA No. 2106/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 83
A motorcycle sub-dealer from the Panchmahal district, Gujarat, has secured a fresh opportunity before tax authorities after the Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) set aside an addition of ₹97.35 lakh towards unexplained cash deposits, while imposing a cost of Rs 10,000 for earlier non-compliance. A coram of Judicial Member Siddhartha Nautiyal and Accountant Member Narendra Prasad Sinha observed that the addition was made largely due to non-compliance and lack of evidence, holding that “the issue requires fresh examination at the level of the Assessing Officer” and that “one more opportunity should be granted to the assessee to substantiate his claim.”
ITAT Ahmedabad Upholds Reopening of IT Assessment On Cash Deposits, Orders Peak Credit Taxation
Case Title : Kanubhai Ambalal Patel v. Income Tax Officer
Case Number : ITA No. 1939/Ahd/2025
CITATION : 2026 LLBiz ITAT(AHM) 84
The Ahmedabad Bench of the Income Tax Appellate Tribunal has upheld the reopening of the assessment of an individual for AY 2016–17 based on cash deposit information but directed that only the peak credit in his bank account be taxed, noting that taxing the entire deposits would be excessive. A coram comprising Judicial Member Siddhartha Nautiyal and Accountant Member Narendra Prasad Sinha held that the reopening was valid as it was based on tangible material, observing that “such information constituted tangible material… suggesting escapement of income.”
Notings In Seized Excel Sheet Alone Cannot Justify "Bogus" Expenditure Addition: ITAT Ahmedabad
Case Title : ACIT, Central Circle-2, Vadodara v. HK Ispat Pvt. Ltd. & Ors.
Case Number : IT(SS)A Nos. 73–78/Ahd/2025 & connected appeals
CITATION : 2026 LLBiz ITAT(AHM) 85
The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) has held that transactions already recorded in regular books of account cannot be treated as “bogus” expenditure solely based on entries in a seized Excel sheet. A Bench comprising Vice President Dr. B.R.R. Kumar and Judicial Member Suchitra R. Kamble, on 18 March, upheld the deletion of additions made by the Assessing Officer, holding: “There is no reason for us to believe that a notation in a planning sheet represents a 'bogus' expense when the corresponding amount is clearly reflected in the audited books of account and the bank-verified trail.”
OTHER DEVELOPMENTS
CBDT Clarifies Principal Commissioner Can Condone Delay In Filing Form 10A
The Central Board of Direct Taxes (CBDT) has clarified that the jurisdictional Principal Commissioner of Income-tax or Commissioner of Income-tax may condone delay in filing Form 10A for registration of trusts and institutions under the Income Tax Act, 1961. The Board issued the clarification through Circular No. 01/2026 dated 23 March 2026 to resolve ambiguity regarding the competent authority to condone such delay.