This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
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S. 80M: Inter-corporate dividend-Shares held as stock-in-trade-Commercial business expenses cannot be deducted a second time on an estimated basis under the head of other sources to reduce statutory deductions. [S. 14A, 115BBB, 260A]

Pr. CIT v. ICICI Securities Primary Dealership Ltd. (2026) 349 CTR 487 (Bom) (HC)

S. 80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Transfer pricing-Captive power plant supplying electricity to non-eligible manufacturing units-Internal transfer pricing must be benchmarked against the landed cost of electricity supplied to consumers by the State Electricity Board-Benchmarked transaction using internal CUP method adopting average annual landed cost of electricity paid by its manufacturing units to State Electricity Boards (SEBs), since CPPs were established for captive use and not for sale to SEBs, internal CUP was the most appropriate method for determining ALP. [S. 80IA(8), 92BA, 92C, 92F(ii); R. 10B(1)(a)]

Pr. CIT v. Rungta Mines Ltd. [2025] 176 taxmann.com 410 / (2026) 349 CTR 674 (Cal)(HC)

S. 69B: Amounts of investments not fully disclosed in books of account-Protective assessment-Assessment proceedings in respect of the same were concluded, significance of the protective assessment was lost, and the Petitioner could not make a further claim in respect of the same before the authorities. [S.132, Art. 226]

Lakshmi R. Nair v. PCIT [2025] 178 taxmann.com 413/ (2026) 349 CTR 467 (Ker)(HC)

S. 69B: Amounts of investments not fully disclosed in books of account-Rejection of books and reference to DVO-Addition was affirmed. [S.69A, 142A, 260A]

Ravindran M. v. ITO (2026) 349 CTR 774 / 310 Taxman 611 (Mad)(HC)

S. 69: Unexplained investments-Addition-Stock statement furnished to bank-Statement linked to overdraft facility and drawing power-Addition sustained. [S.4, 260A]

Loomba Manufacturing Syndicate v. CIT (2026) 349 CTR 739 / 310 Taxman 39 (P&H)(HC).

S. 69: Unexplained investments-Natural justice-Addition made by the A.O. without furnishing the details of information received from CBEC was set aside-Matter was remanded with a direction to provide such details and grant sufficient time and opportunity of personal hearing to the assessee. [S.69A, 143(3), 144B, Art.226]

JSW Minerals Trading (P1 Ltd. v. AUIT [2026] 183 taxmann.com 28/ 349 CTR 645 (Bom)(HC)

S. 68: Cash credits-Share application money-Failing to establish genuineness and creditworthiness-Addition sustained. [S. 260A]

Liquors India Ltd. v. ACIT (2026) 349 CTR 113 / 183 taxmann.com 357 (Telangana)(HC).

S.54F: Capital gains-Investment in a residential house-No prohibition for using borrowed funds for construction, which would be later settled using sale consideration deposited in the Capital Gains Account Scheme; however, this should be demonstrated with materials to the concerned tax authority.[S. 45, Art. 226]

Sainaba Hamza Koya (Mrs.) v. ITO. [2025] 180 taxmann.com 548 / (2026) 349 CTR 28 (Ker)(HC)

S. 54EC: Capital gains-Investment in specified bonds-Investment made before sale of property-Exemption restricted to capital gain available on date of investment. [S. 45, 260A]

CIT v. K. Kumaran [2025] 173 taxmann.com 838 / (2026) 349 CTR 343 (Mad)(HC).

S. 45 : Capital gains: Computation-Sale consideration-Assessing Officer entitled to substitute actual consideration for consideration stated in sale deed when supported by evidence.[S.48, 260A]

Inderpal Singh Ahuja v. AO (2026) 349 CTR 724 (P&H)(HC). ACIT v.Inder Pal Singh Ahuja (2026) 349 CTR 724 (P&H)(HC).