Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


PCIT v. HDFC Bank Ltd. [2025] 173 taxmann.com 579 (Bom) (HC) Editorial: SLP of revenue dismissed, PCIT v. HDFC Bank Ltd. [2025] 304 Taxman 606 (SC)

S. 37(1): Business expenditure-Broken period interest-Securities held as stock-in-trade-Deduction allowable.[S.145, 260A]

Saigal Sea Trade v. ACIT [2025] 176 taxmann.com 75 (Bom) (HC).

S. 37(1): Business expenditure-Personal element-Disallowance-Pure finding of fact-Commission payment-Services not established-Finding of fact-No substantial question of law.[S.260A]

PCIT v. ICICI Securities Ltd. [2025] 174 taxmann.com 160 (Bom) (HC)

S. 37(1) : Business expenditure-Client assistant charges-Three-in-one account scheme-Expenditure incurred for business allowable-Provision for loss-Contingent liability-Conservative principle-Deduction allowable [S. 145, 260A]

PCIT v. Watson Pharma (P.) Ltd. [2025] 173 taxmann.com 957 (Bom) (HC)

S. 36(1)(vii) : Bad debt-Advances-Business loss-Write-off of unrecovered advances-Genuineness not disputed-Deduction allowable. [S,28(i), 260A]

PCIT v. Morgan Stanley India Capital Pvt Ltd [2025] 177 taxmann.com 699 (Bom) (HC)

S.14A: Disallowance of expenditure-Exempt income-Interest-free funds-Non-interest-bearing funds were more than the investment made in tax-free securities; it would be presumed that the investment made by the assessee would be from its interest-free funds and, thus, no disallowance under section 14A could be made-Order of Tribunal affirmed. [S.260A, Rule 8D]

PCIT v. Mahindra Engineering Services Ltd. [2025] 180 taxmann.com 759 (Bom)(HC)

S. 10A: Free trade zone-STP Unit-New infrastructure, plant and machinery, software and separately recruited workforce-Undertaking not formed by splitting up or reconstruction of existing business-Deduction allowable-Order of Tribunal affirmed. [S. 10A(2), 260A]

Vidya Sagar Sharma v. UOI(2026) 349 CTR 121 /184 taxmann.com 44 (J&K)(HC)

Direct Tax Vivad Se Viswas Act, 2024.
S 91 : Filing of declaration and particulars to be furnished-Prior tax position revived when assessee does not comply with provisions / requirements of DTVSV Act 2020 and hence eligible under DTVSV Act 2024.[DTVSV Act, 2020, S. 4(6), 5(1)Art. 226]

Shiv Kumar Jaiswal v. State of UP. (2026) 349 CTR 228/ 182 taxmann.com 684 (All)(HC)

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-When the subject matter of the penalty, which was the very basis on which criminal proceedings had been launched, was set aside, criminal proceedings could not be allowed to continue.[S.271(1)(c), 277]

Jyotsana Investments Co. Ltd. v. R.K De (2026) 183 taxmann.com 293 / 349 CTR 406(Cal)(HC)

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Revenue had accepted statutory compounding fee under section 279 in relation to alleged offences under sections 276B and 278B-Continuation of criminal proceedings after such compounding constituted abuse of process and liable to be quashed. [S. 278B, 279, Art.21, 226]

Venkateshan R.V. v. Sanjay @ Sanjay Sait & Ors. (2026) 349 CTR 105 / 182 taxmann.com 845 (Mad)(HC)

S. 269ST: Mode of undertaking transactions-Intimation of heavy cash transaction to jurisdictional Income Tax Authorities in civil recovery suits pursuant to Supreme Court guidelines-Assessee could not be compelled to reveal his PAN to the debtors. [S.271DA]