S. 139 : Return of income—Tax audit report—Specified date—Extension of due date—CBDT Circular No. 14 of 2025 extending only the “specified date” without extending the “due date” is contrary to Expln. (ii) to s. 44AB and legislative intent—There must statutorily remain a gap of one month between the tax audit report date and return filing due date—CBDT directed to extend due date for filing return to 30-11-2025 for assessees liable to furnish audit report for AY. 2025-26.[S. 44AB, 119, 139(1), 139(2), Art. 226]

S. 139 : Return of income-Tax audit report-Extension of due date-Technical glitches on e-filing portal-Delayed release / intermittent functioning of utilities-Sharp fall in number of tax audit reports filed as compared to earlier year-Extension granted for individual ITRs also relevant-Significant hardship to assessees and professionals justified judicial intervention-As an interim measure, due date for filing tax audit reports for A.Y. 2025-26 extended from 30-9-2025 to 31-10-2025. [S. 44AB, 119, Art. 226]

S. 132A : Powers-Requisition of books of account-Search and seizure-Cash and seizure of articles-Seizure of jewellery by Sate Survellance Team (SST) of District Election Officer and handing over to IT Department— Logistics company-Application for release of seized assets Consignments of jewellery seized by Static Surveillance Team under guidelines issued by Election Commission and handed over to Income-tax Department-Non-recording of satisfaction note-Reassessment notice was quashed-The application filed by the AT Jewellers was liable to be considered by the AO, i.e. Dy. CIT, Central-2.Apart from AT Jewellers, whoever is the consignee claiming ownership and release, may submit an application before the same AO-Writ petitions are allowed with a direction to the Dy. CIT, Central-2 to release the jewellery consignments-Cost of Rs.50000 was awarded in favour of all the writ petitioners payable by the respondents severally and jointly.[S. 127, 131,132,147, 148, Art. 226]

S. 132 :Search and seizure—Reason to believe-Three lockers-Jewellery and bullion worth in crores-Sufficiency of the information for forming the reasons to believe is cannot be examined in writ proceedings-Writ petition dismissed.[S. 132(1), 132(3), Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Delay in filing Form No 9A-Misprint contained in taxman publication-Delay was condoned-Directed to grant the exemption. [S.11(1)(a), 11(7), 119(2)(b), 139,Form 9A, Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Belated revised return of income-Condonation of delay—Reasonable cause-Mistake by chartered accountant—Rectify error in Tax Audit Report pertaining to due date of payment of employees contribution to PF/ESI-Incorrect dates in Form 3CD–On writ thee Court held that Principal Commissioner ought to have condoned delay in filing return of income by assessee.[S 36(1)(va), 43B, 119(2(b). Form No 3CD, Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Property held for charitable purposes-Audit report in Form 10B could not be uploaded with return due to inadvertent error of auditor-Delay was bona fide-Delay was condoned-Commissioner was directed to pass a fresh order in accordance with law. [S. 12A, 139,119(2)(b), 143(1), 154, Form 10B, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-SEZ unit-Assessing Officer could not deny section 10AA exemption on portion of income relating to these TP adjustments, since income was not enhanced by Assessing Officer and conditions of section 92C(4) proviso were not attracted.[S.10AA, 92C(4), 260A]

S. 80IB(10) : Housing projects-Bunglows which were duplexes surrendered by copaund wall-Portico and open terarace-Open terrace and portico was an area which was otherwise totally open and exposed and could not be brought within purview of inner measurement of residential unit-Two areas had to be excluded from computation of built-up area entitling assessee to benefit under section 80IB(10) of the Act. [S. 260A]

S. 80-IB(10) : Housing project-Built-up area-Flower bed area, being below floor level, open to sky, outside residential unit and not habitable, cannot be included in “built-up area”-Cupboard projections already forming part of wall area, service area being common utility duct area, and window projections at sill level being unsafe/elevational features also not includible-Tribunal justified in directing allowance of deduction under section 80-IB(10)-Order affirmed. [S. 80-IB(14)(a), 260A]