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–reassessment–trader in diamonds-Information from Investigation wing-Bogus purchases-Commission agent –Bhanwarlal Jian-Books of account not rejected-Order of Tribunal estimating at six per cent is affirmed. [S. 132(4), 147, 148, 260A]

Gyanchand S. Jain (proprietor of Sanjana Exports) v. ITO (2025) 483 ITR 377 (Guj)(HC)

S. 56 : Income from other sources-Grants received by statutory corporation from Government for construction of housing for Police Department-Interest on deposit of such grant amounts in banks-Assessable as income from other sources-Interest paid not allowable as deduction. [S. 36(1)(iii)]

Bihar Police Building Construction Corporation Pvt. Ltd v. PCIT [2023] 157 taxmann.com 495 / (2025) 483 ITR 203 (Patna)(HC) Editorial : SLP dismissed, Bihar Police Building Construction Corporation Pvt. Ltd v. PCIT [2025) 303 Taxman 335 (SC)

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Capital or revenue-Pre-payment of deferred sales tax liability-Capital receipt.[S. 4, 260A]

CIT v. Grindwell Norton Ltd (2025) 483 ITR 651 (Bom)(HC)

S. 40A(3): Expenses or payments not deductible-Cash payments exceeding prescribed limits-Amendment with effect from 1-4-2009-Disallowance of payments exceeding specified limit to a single person on a single day-No evidence of separate payments made on a single day to assessee-Disallowance justified. [R.6DD]

Mahendra Prasad Singh and Bros. Mahalla v. CIT [2024] 160 taxmann.com 233 / (2025) 483 ITR 479 (Patna)(HC)

S. 32: Depreciation-Intangible assets-Business and commercial brand equity are goodwill-Depreciation allowable. [S. 260A]

CIT v. Grindwell Norton Ltd (2025) 483 ITR 651 (Bom)(HC)

S. 28(i): Business income-Capital or revenue-Subsidy-Exemption from sales tax granted by State Government-Assessable as revenue receipt.[S. 4, The U.P. Trade tax Act, 1948, S. 4A, 8A(2) 29A]]

CIT v. Birla Corporation Ltd [2024] 159 taxmann.com 632 / (2025) 483 ITR 554 (Cal)(HC)

S.14A : Disallowance of expenditure-Exempt income-Restriction of disallowance to the extent of two per cent. of dividend income Proper-Reserves and surplus amount exceeding investment-Presumption that investments out of own interest-bearing funds Disallowance not attracted.[S. 36(1)(iii) R.8D, 260A]

CIT v. Grindwell Norton Ltd (2025) 483 ITR 651 (Bom)(HC)

S.14A : Disallowance of expenditure-Exempt income-No borrowed funds utilised for investment-Order of Tribunal deleting the disallowance affirmed.[R.8D(2)(iii)]

PCIT v. Inductis India Pvt. Ltd(2023) 157 taxmann.com 87 / (2025) 483 ITR 492 (Delhi)(HC) Editorial : PCIT v. Inductis India Pvt. Ltd [2025] 175 taxmann.com 423 (SC), SLP dismissed on account of delay of 387 days.

S. 10 (23C): Educational institution-Ancillary activities were connected with the main activity of imparting education-Nominal profit earned was again utilised for the main object of education-Entitled to exemption. [S. 10(23C)(vi), 260A]

CIT (E) v. Star Education Trust.(2025) 483 ITR 268 (Guj)(HC)

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Non-resident-Providing registration for a domain name-Fees received not assessable as royalty-DTAA-India-USA (1991) 187 ITR (St.) 102). [S.260A, Art. 12(3)(a)]

GoDaddy.com LLC v. ACIT [2023] 157 taxmann.com 256 / (2025) 483 ITR 515 (Delhi)(HC)