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. 69C: Unexplained expenditure-Bogus purchases-Restricting addition to the extend of seven percentage of alleged bogus purchases-No question of law-Order of Tribunal was affirmed. [S.37(1), 69C, 260A].

PCIT v. Pravin U. Parmar (Jain) (2025) 474 ITR 171 (Bom)(HC)

S. 69C: Unexplained expenditure-Bogus purchases-Information from sales tax department-Suspicious dealers-Only profit attributable on total purchase consideration could be subject to income-tax-Not entire purchase.[S. 260A]

PCIT v. Bharat Copy Centre (P.) Ltd. [2023] 155 taxmann.com 211 (Bom)(HC)

S. 69C : Unexplained expenditure-Bogus purchases-Tribunal justified in restricting addition to 8% GP on impugned purchases, as purchases were genuine and paid by cheque. [S. 133(6),
260A]

PCIT v. Hiren C. Parekh [2023] 153 taxmann.com 470 (Bom)(HC)

S. 69C : Unexplained expenditure-Bogus purchases-No discrepancy between purchases and sales-Entire bogus purchases could not be treated as income; addition restricted to GP element. [S. 260A]

PCIT v. Dhondiram Naryan Limbhore [2023] 153 taxmann.com 539 (Bom)(HC) Editorial : SLP of revenue dismissed due to delay of 628 days and also on merits, PCIT v. Zahira R. Khatun [2025] 304 Taxman 514 (SC).

S. 69A : Unexplained money-Seizure at airport-Professional income explained-Competent authority was directed to return seized cash. [S. 131(1A),Art. 226]

Ramchandra K. Mendadkar v. UOI [2023] 154 taxmann.com 440 (Bom)(HC)

S. 69A : Unexplained money-Accommodation bills-Burden of proof-Assessee was not obliged to produce third-party books-Order of Tribunal deleting the disallowance was affirmed.[S. 260A]

PCIT v. M. Dinshaw & Co. (P.) Ltd. [2023] 156 taxmann.com 170 (Bom)(HC)

S. 45 : Capital gains-Sale of shares-Computation of capital gains-Fair market value as on 01-04-1981-Leasehold land-lease value of leasehold interest to be taken into account.[S. 2(22B), 55(2)(b)(ii), Wealth-tax Rules, 1957.R. 1D]

PCIT v. Dr. Karan Singh, (2025) 474 ITR 446 (J&K and Ladakh) (HC)

S. 40(a)(ia): Amounts not deductible-Deduction at source-Contractors-Declaration was furnished-Tribunal was not justified in remanding the issue before the Assessing Officer. [S. 194C(6), 254 (1) 260A]

Unitac Energy Solutions (India) Pvt. Ltd v. ACIT (2025) 474 ITR 265 (Ker)(HC)

S.37(1): Business expenditure-Provision for claims made on customer wise details-Not a contingent liability-Provision for incurred but not reported claims allowable as deduction. [S.260A, First Schedule]

PCIT v. Care Health Insurance Ltd. (earlier Religare Health Insurance Co. Ltd.) [2024] 164 taxmann.com 53 / (2025) 474 ITR 402 (Delhi)(HC)

S.37(1): Business expenditure-Statutory reserve fund-Amounts transferred to statutory reserve fund in compliance with mandatory provisions of Reserve Bank of India Act, 1934-No diversion of income-Not allowable as deduction.[S. 4, Reserve Bank of India Act, 1934 S. 45-IC, 45Q.]

Shriram City Union Finance Ltd. v. ACIT (2025) 474 ITR 514 (Mad)(HC)