High Court income-tax judgments and orders

70 records in this corrected batch, with original PDFs and individual three-page notes. Distinct cases covered by a common judgment are retained. Coverage is selected; subsequent judicial treatment is unverified.

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70 records

Pr. Commissioner of Income Tax-15 v. Zydus Nycomed Healthcare Pvt. Ltd.

High Court of Judicature at Bombay · 2026-10-08 · Income Tax Appeal No. 2892 of 2018

Section 10B(7) read with section 80-IA(10): reduction of EOU exemption on drug intermediates sold to joint-venture partner cannot be sustained without establishing an 'arrangement' to produce excessive profits; pricing determination is a question of fact.

Principal Commissioner of Income Tax-2, Kolkata v. Superdeal Resources Private Limited

High Court at Calcutta · 2026-10-05 · ITAT No. 162 of 2026 with GA No. 2 of 2026

Section 68 addition of Rs. 9.32 crore on sale of unlisted equity shares deleted; Pr. CIT v. Swati Bajaj distinguished where documentary record and section 133(6) replies stood uncontroverted.

Raj Pal Katyal v. The Commissioner of Income Tax

High Court of Delhi · 2026-10-01 · ITA 1215/2005 & CM APPL. 44560/2026

Section 68 cash credits: addition of Rs. 7,00,000 on unsecured loans upheld where two alleged lenders denied advancing any loan upon examination by the AO and two others could not explain preceding cash deposits in their bank accounts; cheque payment alone does not prove creditworthiness.

Principal Commissioner of Income Tax-10 v. Bal Kishan Arora

High Court of Delhi · 2026-09-29 · ITA 124/2026; CM APPL. 9589/2026 and 50835/2026

Revenue appeal challenging ITAT order on long-term capital gains / penny-stock addition dismissed as squarely covered by PCIT-12 v. Smt. Krishna Devi, (2021) 126 taxmann.com 80 (Delhi).

The Pr. Commissioner of Income-Tax-1 & Anr. v. AMD India Private Limited

High Court of Karnataka · 2026-09-24 · Income Tax Appeal No. 97 of 2026 c/w Income Tax Appeal No. 96 of 2026

Transfer pricing & section 28(iv): Rs. 200-crore upper turnover filter, Cash PLI (excluding depreciation variance), inclusion of bad-debt provision in operating cost under Rule 10B(1)(e), and deletion of section 28(iv) addition on free-of-cost testing equipment from AE upheld.

The Commissioner of Income Tax - International Taxation - 3 v. Travelport International Operations Ltd.

High Court of Delhi · 2026-09-23 · ITA 212/2025, ITA 219/2025 & ITA 233/2025

Attribution of 15% of revenue to the Indian permanent establishment of a global CRS/GDS provider upheld following Supreme Court precedent in Travelport L.P. USA where distribution fees paid in India exceeded attributed profits.

The Royal Bank of Scotland, N.V. v. Director of Income Tax (International Taxation), Kolkata

High Court at Calcutta · 2026-09-22 · ITA 257 of 2007 with GA 1 of 2014 (Old No. 3593 of 2014)

Foreign bank PE: higher corporate tax rate valid under section 90 Explanation 1 & India-Netherlands DTAA Art. 24(2); interest paid to HO disallowed u/s 40(a)(i) for non-deduction of TDS while interest received from HO remains taxable under separate-entity fiction.

The Royal Bank of Scotland, N.V. v. Commissioner of Income Tax, Kolkata III

High Court at Calcutta · 2026-09-22 · ITA 191 of 2006 with GA 1 of 2014 (Old No. 3589 of 2014)

Foreign bank PE (AY 1999-2000 main appeal): four substantial questions answered for Revenue—foreign-company tax rate valid under section 90 Explanation 1 & India-Netherlands DTAA Art. 24(2); branch-to-HO interest of Rs. 99.77 lakh disallowed u/s 40(a)(i) & taxable in HO hands; and Rs. 1.52 crore HO-to-branch interest receipt taxable in PE hands.

The Royal Bank of Scotland, N.V. v. Director of Income Tax (International Taxation), Kolkata

High Court at Calcutta · 2026-09-22 · ITA 699 of 2007 with GA 1 of 2014 (Old No. 3327 of 2014)

Foreign bank PE (AY 2003-04): (1) Higher foreign-company tax rate valid under Explanation to section 90 & Article 24(2); (2) Rs. 99.77 lakh interest paid by Indian PE to head office disallowed under section 40(a)(i) for non-deduction of section 195 TDS; (3) Interest received by PE from head office/branches taxable under Article 7 separate-entity fiction; (4) ATMs qualify as 'computers' eligible for higher depreciation.

The Royal Bank of Scotland, N.V. v. Director of Income Tax, International Taxation, Kolkata

High Court at Calcutta · 2026-09-22 · ITA 439 of 2007 with GA 1 of 2014 (Old No. 3329 of 2014)

Automated Teller Machines (ATMs) qualify as 'computers' under Item 2B of Appendix I to the Income-tax Rules for higher depreciation (Question 4 answered for assessee), while foreign-bank tax rate, branch-to-HO interest disallowance u/s 40(a)(i), and HO-to-branch interest taxability are answered for Revenue (Questions 1–3).

The Pr. Commissioner of Income Tax & Anr. v. M/s. Synamedia India Pvt. Ltd. (formerly Cisco Video Technologies India Pvt. Ltd.)

High Court of Karnataka · 2026-09-17 · Income Tax Appeal No. 22 of 2021

Transfer pricing under section 92C and Rule 10B (AY 2012-13): applying the 10-point framework in Sap Labs India Pvt. Ltd. (ITA No. 10/2011), exclusion of Persistent Systems Ltd. and Larsen & Toubro Infotech Ltd. from the comparable set upheld as a non-perverse finding of fact.

The Pr. Commissioner of Income Tax & Anr. v. M/s. Applied Materials India Pvt. Ltd.

High Court of Karnataka · 2026-09-17 · Income Tax Appeal No. 36 of 2021

Transfer pricing comparability under section 92C and Rule 10B: exclusion of Mindtree Ltd., Persistent Systems Ltd., and Larsen & Toubro Infotech Ltd. from captive service provider's comparable set upheld as functionally dissimilar and non-perverse.

Commissioner of Income Tax-III & Anr. v. M/s Torry Harris Business Solutions Pvt. Ltd.

High Court of Karnataka · 2026-09-16 · Income Tax Appeal No. 155 of 2015

Transfer pricing under section 92C & Rule 10B (AY 2009-10): Rs. 1–200 crore turnover filter upheld under Sap Labs India; Bodhtree Consulting Ltd. (software product company) excluded even though initially proposed by assessee; exclusion of comparables by ITAT does not warrant a fresh TPO search.

The Pr. Commissioner of Income Tax, Central & Anr. v. M/s. Sami Sabinsa Group Ltd.

High Court of Karnataka · 2026-09-15 · Income Tax Appeal No. 148 of 2026

Transfer pricing under section 92C & Rule 10B: Internal TNMM must be preferred over external comparables where AE and non-AE segmental financials are derived from audited books using actual invoice-level sales and certified by a Chartered Accountant (11.32% AE margin vs. 2.42% non-AE margin).

The Pr. Commissioner of Income-Tax, Central & Anr. v. Global Tech Park Pvt. Ltd.

High Court of Karnataka · 2026-09-10 · Income Tax Appeal No. 2 of 2026

Section 153A search assessment: addition of Rs. 10 crore based solely on uncorroborated figures scribbled by CFO on loose sheets (explained as loan-eligibility calculations for property acquisition) deleted; loose sheets are not books of account under V.C. Shukla and Sunil Kumar Sharma.

The Pr. Commissioner of Income-Tax, Central & Anr. v. M/s. Atria Wind (Kadambur) Pvt. Ltd.

High Court of Karnataka · 2026-09-09 · Income Tax Appeal No. 139 of 2026

Section 47(xiii) provisos (a) & (c) and section 153A: partner capital withdrawal and share sale prior to firm-to-company conversion do not violate 'immediately before the succession' condition; regular corporate documents (Board resolutions, legal notes, valuation reports) are not incriminating material under Abhisar Buildwell.

The Commissioner of Income-Tax & Anr. v. M/s. Cisco Systems (India) Pvt. Ltd.

High Court of Karnataka · 2026-09-08 · Income Tax Appeal No. 140 of 2014

Transfer pricing most appropriate method under section 92C & Rule 10B (AY 2008-09): Rs. 128.79 crore RPM adjustment on warranty/AMC spare replacement services set aside; custodian delivering spares at NIL price for 1% markup is a service provider benchmarkable under TNMM.

The Commissioner of Income-Tax & Anr. v. M/s. Cisco Systems (India) Pvt. Ltd.

High Court of Karnataka · 2026-09-08 · Income Tax Appeal No. 379 of 2013

Transfer pricing most appropriate method under section 92C & Rule 10B (AY 2007-08): captive entity importing warranty/AMC replacement spares from US AE and delivering them to AE's Indian customers at NIL price for a 1% markup is a service provider benchmarkable under TNMM, not a trader under Resale Price Method (RPM).

The Pr. Commissioner of Income-Tax, Central & Anr. v. Bileshivale Muddanna Govardhana Murthy

High Court of Karnataka · 2026-09-08 · Income Tax Appeal No. 141 of 2026

Section 2(47)(v) / section 53A Transfer of Property Act & section 153A: LTCG additions of Rs. 79.61 lakh and Rs. 17.51 crore on ancestral HUF land under a Joint Development Agreement deleted where subsequent civil court partition decree allotted the JDA land to other family members and assessee's unconverted agricultural share remained untransferred.

Sap Labs India Private Limited v. The Income Tax Officer, Ward-12(2), Bangalore & Connected Appeals

High Court of Karnataka · 2026-08-28 · ITA No. 10 of 2011 c/w ITA Nos. 23/2011, 24/2011, 44/2015, 128/2015, 469/2015, 492/2016, 514/2016, 884/2017, 955/2017, 956/2017 & IT Appeal Cross Objection No. 1 of 2018

Landmark 121-page post-SC-remand Transfer Pricing ruling laying down 10 principles under Chapter X and Rule 10B: Rs. 200-crore upper turnover filter, 15% RPT filter, forex gain/loss operating nexus, shifting burden under section 92C(3), ±5% tolerance band, working capital adjustment, and comparable-by-comparable adjudication.

Solize Partners India Pvt. Ltd. v. The Income Tax Officer, International Taxation, Ward 1(1), Bangalore

High Court of Karnataka at Bengaluru · 2026-08-06 · Income Tax Appeal No. 181 of 2014

Payments by Indian reseller to non-resident software owners for purchase of standardized/shrink-wrapped computer software licenses do not constitute 'royalty' under section 9(1)(vi) or DTAA Article 12; Engineering Analysis applied.

Sri Venkataramanappa v. The Income Tax Officer, Ward-3(2)(3), Bangalore

High Court of Karnataka at Bengaluru · 2026-07-31 · Income Tax Appeal No. 284 of 2022

Failure by AO to pass a speaking order disposing of assessee's objections to section 148 reopening as required by GKN Driveshafts vitiates the reassessment order but does not obliterate initial section 148 jurisdiction; ITAT rightly remanded to AO to dispose of objections first.

The Pr. Commissioner of Income-Tax, Central & Anr. v. M/s Dream Logistics Company Ltd.

High Court of Karnataka at Bengaluru · 2026-07-30 · Income Tax Appeal No. 28 of 2025

Section 41(1) addition of Rs. 2.60 crore as cessation of trading liability towards M/s Megha Minerals rightly deleted where liability was discharged by cheque on 21.04.2010, no cash-back was proved, and third-party statement was untested by cross-examination.

The Commissioner of Income Tax, CIT(A) Exemption & Anr. v. M/s. Ananda Social and Education Trust

High Court of Karnataka at Bengaluru · 2026-07-30 · ITA No. 167 of 2022 c/w ITA No. 107 of 2022

Following lead judgment in ITA Nos. 112/2022 & 168/2022, Revenue's appeals for AY 2014-15 challenging deletion of alleged unaccounted UG/PG/COMED-K fee additions dismissed.

The Commissioner of Income-Tax (Exemptions) & Anr. v. M/s. Ananda Social & Education Trust

High Court of Karnataka at Bengaluru · 2026-07-29 · I.T.A. No. 112/2022 c/w I.T.A. No. 168/2022

Lead judgment (AY 2009-10): Section 153A additions for alleged unaccounted medical college capitation fees on MBBS Management/NRI quota, PG courses, and COMED-K cancellation seats based on uncorroborated loose sheets, visitors' slips, and PA's diary rightly deleted by ITAT.

The Commissioner of Income-Tax (Exemptions) & Anr. v. M/s. Anand Social and Education Trust

High Court of Karnataka at Bengaluru · 2026-07-29 · ITA No. 110 of 2022 c/w ITA No. 114 of 2022

Following lead judgment in ITA No. 112/2022 (AY 2009-10), Revenue's appeals for AY 2011-12 challenging deletion of alleged unaccounted UG/PG/COMED-K fee additions dismissed.

The Commissioner of Income-Tax (Exemptions) & Anr. v. M/s. Anand Social and Education Trust

High Court of Karnataka at Bengaluru · 2026-07-29 · ITA No. 108 of 2022 c/w ITA No. 164 of 2022

Following lead judgment in ITA No. 112/2022 (AY 2009-10), Revenue's appeals for AY 2008-09 challenging deletion of alleged unaccounted UG/PG/COMED-K fee additions dismissed.

Pr. Commissioner of Income Tax - Central-1 v. SpiceJet Limited

High Court of Delhi · 2026-07-23 · ITA 539/2026 & ITA 540/2026

Aircraft supplemental rent for airframe/engine overhaul is deductible revenue expenditure under section 37(1); rule of consistency across assessment years.

Commissioner of Income Tax, International Taxation-1, New Delhi v. Ernst and Young U.S. LLP

High Court of Delhi · 2026-06-18 · ITA 423/2025, ITA 424/2025, ITA 715/2025, ITA 753/2025 & ITA 760/2025

India-US DTAA Article 12: centralised global IT support, software licence cost-sharing, and network referrals neither constitute Royalty nor satisfy the 'make available' threshold for FIS.

Principal Commissioner of Income Tax, Madurai v. Shri Ganesan Anbuselvam

High Court of Judicature at Madras · 2026-06-12 · T.C.A. No. 40 of 2026

Section 69C unexplained expenditure addition of Rs. 2,27,76,680 deleted where CIT(A) admitted additional evidence under Rule 46A and the Assessing Officer in his remand report verified and accepted that the bank deposits and purchases were consistent with the assessee's retail business.

Principal Commissioner of Income Tax, Madurai v. Chokkalingam Thangavel

High Court of Judicature at Madras · 2026-06-12 · T.C.A. No. 38 of 2026

Section 148 reassessment notice issued on 07.04.2022 for AY 2018-19 (beyond 3 years from end of AY) with approval only of Principal Commissioner under section 151(i) instead of Principal Chief Commissioner under section 151(ii) is void for want of jurisdiction.

Pr. Commissioner of Income Tax, Central-I, Mumbai v. Raj Enterprises

High Court of Judicature at Bombay · 2026-06-11 · Income Tax Appeal No. 213 of 2024

ITAT order remanding ex-parte CIT(A) appeal for AY 2016-17 for de-novo consideration in light of ITAT decision for AY 2011-12 raises no substantial question of law under section 260A.

The Pr. Commissioner of Income Tax - Central-1 v. Shahi Exports Pvt. Ltd.

High Court of Delhi · 2026-05-08 · ITA 369/2026 & CM APPL. 30855/2026, CM APPL. 30856/2026

Section 80-IA(8) read with section 92F specified domestic transaction: market value / ALP of captive power supplied to manufacturing units must be benchmarked against State Electricity Board (SEB) industrial consumer tariff, not volatile 15-minute spot rates on IEX.

Commissioner of Income Tax-LTU, Chennai v. M/s. Mahindra Holidays and Resorts (India) Ltd.

High Court of Judicature at Madras · 2026-04-28 · Tax Case (Appeal) No. 1419 of 2010

Timeshare membership fees: 40% 'Advance Payment towards Facilities' deferred over 25/33-year membership tenure is not accrued income in the year of receipt under sections 4, 5 & 145 and AS-9 where contract imposes continuing obligation and 100% liquidated damages.

Commissioner of Income Tax v. M/s Escorts Ltd.

High Court of Delhi · 2026-04-27 · ITA 1427/2006

Section 2(24)(iv) addition of Rs. 1,71,30,343 already taxed in AY 2006-07 cannot be re-litigated; deletions of business-expansion, interest-free loan, section 14A, and product-development disallowances upheld as pure findings of fact.

Anshuman Singh v. Assistant Commissioner of Income Tax (ACIT), Lucknow

High Court of Judicature at Allahabad · 2026-04-22 · Income Tax Appeal No. 16 of 2026

Perversity under section 260A: ITAT order set aside where Tribunal misread paragraph 3 of the reassessment order as paragraph 3 of the original assessment order and erroneously held that books of account were never produced.

VNG Automotive P. Ltd. v. Asstt. Commissioner of Income Tax

High Court of Delhi · 2026-04-10 · ITA 795/2004 & ITA 796/2004

Interest on pre-commencement bank deposits of funds earmarked for committed plant/machinery and technical know-how obligations is a capital receipt reducing project cost under Bokaro Steel, not 'income from other sources' under Tuticorin Alkali; reopening of section 143(1)(a) intimation valid under Rajesh Jhaveri.

Alka Agarwal v. Deputy Commissioner of Income Tax Central Circle 28, Delhi & Anr.

High Court of Delhi · 2026-04-01 · W.P.(C) 4254/2026; CM APPL. 20672/2026 and 20673/2026

Reassessment order under section 147 r/w section 143(3) passed on the very same date as the assessee's reply without considering it set aside for violation of natural justice.

Sunil Kumar Sahoo, Proprietor of M/s. Bhagabati Cashew v. Deputy Commissioner of Income Tax, Circle-1(2), Bhubaneswar and Others

High Court of Orissa · 2026-03-31 · W.P.(C) No. 23165 of 2025

Distinction between 'issuance' of section 148 notice under section 149 and valid 'service' under section 282 as condition precedent to passing a section 147/144 reassessment order; unserved section 148 notice issued within limitation held a curable procedural defect warranting remand rather than void ab initio quashing.

Commissioner of Income Tax (International Taxation)-1, New Delhi v. Alcatel Lucent France (and connected appeals with Alcatel Lucent International)

High Court of Delhi · 2026-03-27 · ITA 259/2026 (CM APPL. 19472/2026), ITA 260/2026 (CM APPL. 19475/2026), ITA 261/2026 (CM APPL. 19493/2026), ITA 264/2026 (CM APPL. 19502/2026), ITA 265/2026 (CM APPL. 19503/2026)

Supply of software embedded in telecom hardware is not taxable as 'royalty' under section 9(1)(vi) of the Act or Article 12 of the India-France DTAA.

Pr. Commissioner of Income Tax (Central), Pune v. Platinum Properties

High Court of Judicature at Bombay · 2026-03-27 · Income Tax Appeal No. 151 of 2024

Section 263 (Explanation 2(a)) revision quashed: developer following project-completion method rightly recognized survey-admitted on-money for 'Spring-II' in AY 2015-16 upon receipt of Occupancy Certificate on 11.12.2014 rather than in AY 2014-15.

Pr. Commissioner of Income Tax (Central)-3, New Delhi v. Oppo Mobiles India (P) Ltd.

High Court of Delhi · 2026-03-17 · ITA 84/2026 (CM APPL. 6933-6935/2026)

Brand Ambassador expenses, advertisement/sales promotion outlays on hoardings and neon signs, and Provision for Warranty held deductible as revenue expenditure following Pepsico India Holdings and Rotork Controls India.

Pr. Commissioner of Income Tax-1 v. M/s Boeing India Pvt. Ltd.

High Court of Delhi · 2026-03-16 · ITA 586/2025 & CM APPL. 69480/2025, CM APPL. 69481/2025

Transfer pricing: employee-secondment reimbursements at actuals cannot be re-characterised into high-margin consultancy services when the underlying secondment contract was accepted.

Pr. Commissioner of Income Tax 2, Pune v. Amcon Construction

High Court of Judicature at Bombay · 2026-03-13 · Income Tax Appeal No. 46 of 2024

Alleged hawala/bogus purchases based on general Sales Tax Department information: restriction of disallowance to 10% profit element upheld where sales were accepted.

M/s. Sanjay Kumar Bijay Kumar v. Principal Commissioner of Income Tax-I, Bhubaneswar and Others

High Court of Orissa · 2026-02-24 · W.P.(C) No. 28067 of 2025

Second reopening under section 148A(3)/148 for AY 2019-20 quashed where the partnership firm inadvertently held two PANs and the ITO had already completed reassessment under section 147 on the Inactive PAN accepting that the Rs. 4,42,47,290 Canara Bank transactions were accounted for and taxed under the Active PAN.

Principal Commissioner of Income Tax, Central-4 v. Maneesh Pharmaceuticals Pvt. Ltd.

High Court of Judicature at Bombay · 2026-02-23 · Income Tax Appeal No. 1033 of 2024 with Interim Application No. 7 of 2026

Search assessment additions (ALP interest adjustment, section 10B disallowance, and section 68 share capital/premium) deleted in absence of incriminating material following Abhisar Buildwell.

Principal Commissioner of Income Tax-1, Kolkata v. Russel Credit Limited

High Court at Calcutta · 2026-02-20 · ITAT 153 of 2025 with IA No. GA 2 of 2025

Section 263 revision quashed: gain of Rs. 12.97 crore on sale of unquoted ICICI Bank preference shares held for 6 years pursuant to Board resolution rightly accepted as LTCG under CBDT Instruction dated 02.05.2016.

Kendrapara College v. Commissioner of Income Tax (Exemption) and Another

High Court of Orissa · 2026-02-19 · WP(C) No. 4169 of 2026

Section 143(1) CPC intimation passed before expiry of the 30-day clarification window and CIT(E)'s section 264 rejection set aside where a government-aided college claimed section 10(23C)(iiiab) exemption in ITR-7 but inadvertently typed '0' in Part-2B(2b).

Jalandhar Sharma v. Income Tax Officer, Keonjhar Ward, Keonjhar & Others

High Court of Orissa · 2026-02-19 · W.P.(C) No. 15935 of 2024

Faceless reassessment order under section 147 r/w section 144B raising Rs. 1,03,57,050 demand on alleged bogus purchases quashed where paragraph 3.5 falsely recorded that the assessee filed no reply despite uploaded replies and documents on record.

Sri Baidyanath Memorial Trust v. Income Tax Officer, Exemption Circle, Bhubaneswar and Others

High Court of Orissa · 2026-02-19 · W.P.(C) No. 1755 of 2026

Orders of ITAT Cuttack and Addl./JCIT(A) Nashik refusing to condone 822-day delay in filing first appeal against section 143(1) CPC intimation (disallowing Rs. 2,60,16,856 charitable exemption) set aside by applying Supreme Court Covid-19 limitation exclusion.

Smt. Madhu Gupta & Ors. v. Commissioner of Income Tax (Appeals) & Anr.

High Court of Delhi · 2026-02-16 · W.P.(C) 2202/2026

Writ petition challenging CIT(A) order under section 250 on the ground that the section 148 notice and assessment were framed against a deceased person dismissed in view of efficacious appellate remedy before ITAT.

SGBL (India) Ltd., Bhubaneswar v. Assistant Commissioner of Income Tax, Central Circle, Cuttack and Another

High Court of Orissa · 2026-02-12 · WP(C) Nos. 26532 and 26534 of 2025

Department directed to disburse balance income-tax refunds along with statutory interest under section 240 read with section 244A up to the actual date of payment within 4 weeks following appeal-effect/rectification orders.

Daimond Plaza Pvt. Ltd., Bhubaneswar v. Assistant Commissioner of Income Tax, Central Circle, Cuttack and Others

High Court of Orissa · 2026-02-12 · W.P.(C) No. 26574 of 2025

Following rectification order under section 154 r/w section 251 giving appeal effect to CIT(A) deletion of section 153A additions for AY 2010-11, Revenue directed to disburse refund with section 240/244A interest up to payment date within 2 weeks.

Commissioner of Income Tax, Chennai v. Indian Overseas Bank

High Court of Judicature at Madras · 2026-02-05 · T.C.A. Nos. 64 & 65 of 2014

Section 271(1)(c) concealment penalty deleted where public-sector bank made a bona fide, fully disclosed double-taxation relief claim under section 90 for its Hong Kong SAR branch.

Sri Susil Nath v. Income Tax Officer, National Faceless Assessment Centre, Income Tax Department, New Delhi and Another

High Court of Orissa · 2026-02-02 · W.P.(C) No. 154 of 2026

Ex-parte faceless scrutiny assessment order under section 143(3) r/w section 144B on high-value motor vehicle purchases set aside where the assessee was incapacitated by severe neurological illness during the notice window.

M/s Tamil Nadu Small Industries Development Corporation Ltd. v. The Income Tax Officer (OSD), Circle III(1), Chennai & Anr.

High Court of Judicature at Madras · 2026-01-29 · TCA No. 259 of 2012

Prior-period industrial estate maintenance expenditure of Rs. 1,64,47,348 (incurred in FY 2002-03 above 4% G.O. ceiling) not deductible in AY 2004-05 under mercantile system, but Revenue directed to consider the genuine expenditure for AY 2003-04 upon filing of revised computation within 4 weeks.

The Commissioner of Income Tax, Chennai v. M/s. Apollo Infrastructure Projects Finance Co. Ltd.

High Court of Judicature at Madras · 2026-01-29 · T.C.A. No. 580 of 2013

Companion appeal disposal following coordinate-bench rulings on section 14A/10(23G) and consequential section 234D interest; source text contains a printed question/reasoning mismatch.

Harinath Sangramappa Kalpe v. Income Tax Officer, Ward 1 & Ors.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-28 · Writ Petition No. 276 of 2026

Section 148 notice issued by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.

Golden Dreams Buildcon Pvt. Ltd. Through Its Director Mudit Vinod Surana v. The Chief Commissioner of Income Tax, Pune & Anr.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-28 · Writ Petition No. 11975 of 2024

Section 148 notice issued by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.

Commissioner of Income Tax, Chennai v. M/s. TICEL Bio Park Limited

High Court of Judicature at Madras · 2026-01-23 · T.C.A. No. 846 of 2013

Substantial questions of law answered in favour of the assessee for AY 2008-09 following the coordinate-bench judgment in the assessee's own case (T.C.A. No. 1035 of 2015 dated 25.08.2020).

Vinit Vishweshwar Kahalekar v. The Principal Commissioner of Income Tax, Nashik-1 & Ors.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 3338 of 2025

Section 148 notice issued by Jurisdictional Assessing Officer (JAO) after 29.03.2022 quashed following Hexaware Technologies Ltd.; Delhi High Court view in T.K.S. Builders not followed.

S.R. Insurance Services Through Its Partner Ravindra Jamnadas Soni v. Income Tax Officer, Ward 2 & Anr.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 177 of 2026

Partnership firm's challenge to JAO-issued section 148 notice allowed following Hexaware Technologies Ltd.

Kalpana Ashok Tapse v. The Principal Commissioner of Income Tax & Anr.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 565 of 2026

Section 148 notice issued by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.

Jai Bhagwan v. The Principal Commissioner of Income Tax-1 & Ors.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 12892 of 2025

Section 148 reassessment notice issued by Jurisdictional Assessing Officer after 29.03.2022 quashed following Hexaware Technologies Ltd.

Gauri Ganesh Steels, A Partnership Firm Through Its Authorized Partner v. The Director General of Income Tax, Pune & Anr.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 567 of 2026

Section 148 notice issued to partnership firm by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.

Ashok Mohanrao Tapse v. The Principal Commissioner of Income Tax & Anr.

High Court of Judicature at Bombay (Aurangabad Bench) · 2026-01-23 · Writ Petition No. 484 of 2026

Section 148 notice issued by Jurisdictional Assessing Officer set aside following Hexaware Technologies Ltd.

Principal Commissioner of Income Tax-2, Kolkata v. M/s Radiant Commercial and Investment Private Limited

High Court at Calcutta · 2026-01-19 · ITAT/192/2025 (IA No. GA/1/2025, GA/2/2025)

Section 68 share-capital addition of Rs. 1,95,50,000 deleted by ITAT; Revenue appeal with Rs. 48,54,112 tax effect held outside Clause 3.1(h) exception to CBDT Circular Nos. 5/2024 & 9/2024.

Commissioner of Income Tax (International Taxation)-3 v. Sri Lanka Cricket

High Court of Delhi · 2026-01-15 · ITA 4/2026 & CM APPL. 2536/2026, CM APPL. 2537/2026

Section 148 reassessment notice by non-jurisdictional officer; no section 9(1)(i) business connection or PE from cricket tournament payments in Sri Lanka.

The Reserve Bank Employees Co-operative Credit Society Limited v. Principal Chief Commissioner of Income Tax, Odisha Region & Others

High Court of Orissa · 2026-01-09 · W.P.(C) No. 7708 of 2025

Refusal under section 119(2)(b) to condone delay in filing returns and audit reports of a cooperative credit society for AYs 2018-19 to 2022-23 quashed where delay was caused by statutory audit pendency before the state Directorate of Cooperative Audit.

Commissioner of Income Tax-I, Chennai v. M/s. TVS Motor Company Ltd.

High Court of Judicature at Madras · 2026-01-05 · T.C.(A). No. 330 of 2011

Seven questions decided for assessee: dies/moulds replacement under section 31(1); temporary office interiors; section 35(2AB) R&D WIP; Entry Tax set-off; Rs. 36.97 cr NPV sales-tax deferral prepayment outside section 41(1); ECB upfront fee outside UK/Singapore DTAA FTS ('make available'); and foreign agent export commission.