Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


CIT v. Laserwords US Inc. [2025] 175 taxmann.com 920 (Mad)( HC)

S. 144C : Reference to dispute resolution panel – Document Identification Number [‘DIN’] – Circulars issued by CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue – DIN has to be generated for DRP proceedings -Order of Tribunal quashing the order is affirmed by High Court – No substantial question of law . [ S. 119, 143(3), 144(5), 260A ]

Mahindra & Mahindra Ltd. v. CIT City – II, Mumbai, [2025] 174 taxmann.com 154 (Bom)( HC)

S. 115J : Company – Book profit – The AO has no jurisdiction to question the correctness of the profit and loss account prepared and certified by the Chartered Accountant .[ Companies Act , 1956 ]

Mahindra & Mahindra Ltd. v. CIT [2025] 174 taxmann.com 154 (Bom)( HC)

S. 37(1)) : Business expenditure – Commercial expediency- Business loss – write-off of the deposits and interest – Amount lent to subsidiary- Allowable as business expenditure .[ S. 28(i) ]

CIT (E) Mumbai v. Kutchi Sarvodaya Nagar [2025] 175 taxmann.com 647 (Bom)( HC)

S. 11 : Property held for charitable purposes – Charitable purpose Objects of general public utility- Construction of flats for its members – Transfer fees from new members – Interest on investment- No commercial activity – No violation of section 13(2) – Question of fact – No substantial question of law . [S. 2(15), 12A, 13(2), 260A]

PCIT v. Watson Pharma Pvt. Ltd [2025] 173 taxmann.com 886 (Bom) (HC)

S. 10B: Export oriented undertakings – Interest income on fixed deposits -Derived from business – Appellate Tribunal – Duty to pass speaking order – Matter remanded back for fresh adjudication .[ S. 254(1), 260A ]

Nilons Enterprises (P) Ltd. v. ITO [2024] 161 taxmann.com 566 ( Pune )( Trib)

S. 271E : Penalty for failure to comply with provisions of section 269T – Adjustments through journal entries for genuine business purposes – Penalty is deleted . [ S. 269SS, 269T, 273B ]

Arvind Aggarwal v. ITO ( Delhi)( Trib) ( UR )

S. 271B : Penalty- Failure to get accounts audited – Applicability of provision of section 271A – Non-maintenance of books of account- Penalty is deleted .[ S.44AA, 44AB , 271A ]

Ankur Goyal v. ITO (2025) 211 ITD 571 ( Delhi)( Trib) ( UR )

S. 69: Unexplained investment – Source investment – Loan from mother and brother – Addition is deleted .

Patel Minerals Pvt Ltd v. ACIT [2025] 172 taxmann.com 287 ( Jodhpur )( Trib)

S. 56: Income from other sources – Share premium received by a private company – DCF Method is a valid method under rule 11UA – No defects pointed out in valuation report- Addition is deleted . [S . 56(2)(viib) , R.11UA ]

Vinod Nihalchand Jain v. ITO [2025] 172 taxmann.com 581 ( Mum)( Trib)

S.45 : Capital gains- Beneficial owner – Co-owner – Entire sale consideration declared in return of income filed by assessee’s brother – Addition can not be made in the hands of assessee.[ S. 54F ]