Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Chhattisgarh Steel Castings (P.) Ltd. v. CIT (2025) 304 Taxman 447 (Chhattisgarh)(HC)

S. 69B : Amounts of investments not fully disclosed in books of account -Survey-Shortage of closing stock of finished goods and raw material-Sales outside books of account- The contention of the assessee that only GP should be added was rejected-On writ High Court affirmed the order of the Commissioner. [S. 264, Art. 226]

PCIT v. Divyaben Prafulchandra Parmar (2025) 304 Taxman 512 (SC) Editorial : PCIT v. Divyaben Prafulchandra Parmar(2024) 169 taxmann.com 473 (Guj)(HC)

S. 68 : Cash credits-Sale of shares-Information received from investigation wing- Sold through recognised stock exchange-Paid Security transaction- Delay of 292 days-SLP dismissed-Delay was not satisfactorily explained. [S. 10(38), 45, Art. 136]

PCIT, Central v. Waterline Hotels (P.) Ltd. (2025) 304 Taxman 487 (Karn)(HC)

S. 56 : Income from other sources -Share premium- DCF method-Order of Tribunal deleting the addition is affirmed. [S. 56(2)(viib), R 11UA(2), 260A]

Trends Pharma v. ITO (2025) 304 Taxman 150 (Bom.)(HC)

S. 48 : Capital gains-Computation-Purchase and sale of shares-Sham transactions-Set off of short term loss against short term capital gains-Order of Tribunal disallowing the loss is affirmed.[S. 45, 260A]

CIT v. Technip Energies Italy S.P.A (2025) 482 ITR 153 / 304 Taxman 346 (SC) Editorial : CIT v. Technip Energies Italy S.P.A (2025) 172 taxmann.com 433/482 ITR 149 (Delhi)(HC)

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Tribunal was justified in holding that expenses claimed by assessee were not excessive and disallowance of assessee’s claim was unsustainable-SLP of revenue dismissed-DTAA -India -Italy. [S. 9(1)(i), Art. 7, Art. 136]

Dy. CIT v. Nitesh Housing Developer (P.) Ltd. (2025) 304 Taxman 517 (SC) Editorial : Nitesh Housing Developer (P.) Ltd(2023) 290 Taxman 474/ 454 ITR 770 (Karn)(HC)

S. 37(1) : Business expenditure-Capital or revenue-Redemption of debentures- Allowable as revenue expenditure -SLP of revenue dismissed. [Art. 136]

CIT v. HDFC Bank Ltd. (2025) 304 Taxman 606 (SC) Editorial: PCIT v. HDFC Bank Ltd(2025) 173 taxmann.com 579 (Bom)(HC)

S. 37(1) : Business expenditure -Securities held as stock in trade -Broken period interest-SLP of revenue dismissed.[Art. 136]

PCIT v. Amadeus India (P.) Ltd. (2025) 304 Taxman 276 (SC) Editorial : PCIT v. Amadeus India (P.) Ltd(2022) 145 taxmann.com 311 (Delhi)(HC)

S. 14A : Disallowance of expenditure-Exempt income-where no exempt income is received or receivable during relevant previous year-SLP of revenue dismissed on account of failure to explain 597 days of delay. [Art. 136]

CIT (E) v. International Health Care Education and Research Institute (2025) 304 Taxman 265 / 482 ITR 287 (SC) Editorial : CIT (E) v. International Health Care Education and Research Institute (2025) 171 tamannn.com 578(Raj)(HC)

S. 12AA : Procedure for registration -Trust or institution- While deciding application for registration the Commissioner cannot comment on genuineness of activities of trsut-Required to restrict to object of trust-SLP of revenue dismissed.[S.12A, Art. 136]

CIT (E) v. Naroda Enviro Projects Ltd. (2025) 304 Taxman 186 (SC) Editorial : CIT (E) v. Naroda Enviro Projects Ltd (2019)419 ITR 482 / (2020) 118 taxmann.com 378 (Guj)(HC)

S. 11 : Property held for charitable purposes-Dominant object was not only preservation of environment, but also one of general public utility- liquid and solid industrial waste generated by polluting industries in Common Effluent Treatment Plant and Total Suspended Disposal Facility and did anciliary activities for purpose of curbing pollution- Entitled to exemption-Monetary limits- SLP dismissed due to low tax effects. [S. 2(15), 268A, Art, 136]