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. 80P: Co-operative societies-Interest received from co-operative banks is eligible for deduction under section 80P(2)(d). [S. 80P(2)(d), 80P(4), 260A]

Sikkim State Cooperative Supply & Marketing Federation Ltd. v. DCIT [2025] 181 taxmann.com 494 / (2026) 348 CTR 122 (Sikkim)(HC)

S. 69A: Unexplained money-Income from Undisclosed Sources-Cash deposits-Partner-Firm-Addition upheld where explanation regarding capital contribution by partners was unsupported by evidence. [S. 254(1)]

Sabbarapu Narayana Rao v. PCIT (2026) 348 CTR 404 (AP)(HC)

S. 44AF : Retail business-Computation-Business income-Presumptive taxation-Return filed under section 44AF cannot be treated as defective for non-furnishing of particulars required under section 139(9)-Entitled to the consequential refund. [S. 44AF, 139(9), Art. 226]

Mohd. Amzad v. ITO [2025] 180 taxmann.com 194 / (2026) 348 CTR 341 (Telangana)(HC)

S. 10(23BBA): Income of any body or authority-Exemption is available only to the statutory body or authority administering religious institutions and not to the institutions themselves. [S. 11, 12, 12A, Art. 226]

Madhur Sree Madanantheswara Vinayaka Temple Administrative Body v. ITO [2025] 181 taxmann.com 506 / (2026) 348 CTR 694 (Ker.)(HC)

S. 271D: Penalty-Takes or accepts any loan or deposit-Failure to record satisfaction-Penalty order was quashed-SLP of revenue dismissed on account of delay of 359 days and also on merits. [S. 269SS, Art. 136]

Jt. CIT v. Grandhi Sri Venkata Amarendra (2026) 309 Taxman 419 (SC) Editorial: Grandhi Sri Venkata Amarendra v. JCIT [2026] 183 taxmann.com 323 (AP)(HC)

S. 271AAB: Penalty-Search cases-Period of limitation-Penalty initiated in the assessment order, which was carried in appeal to the Commissioner (Appeals) and the Tribunal-Limitation governed by section 275(1)(a) and not the residuary clause (c)-Penalty order passed within six months of receipt of the Tribunal’s order is within limitation. [S. 132(4), 275(1)(a), 275(1)(c), Art. 226]

Chandrasekaran Joseph Vijay v. Dy. CIT (2026) 486 ITR 59 / 309 Taxman 335/ 349 CTR 369 (Mad.) (HC)

S.270AA: Immunity from imposition of penalty-Application for immunity from penalty was rejected without considering the assessee’s contentions, or the reasons could not withstand judicial scrutiny and therefore is liable to be set aside. [S. 143(1), 270A(9), Art . 226].

Amalgam Steel (P.) Ltd. v. Asst. CIT (2026) 309 Taxman 174 (Cal)(HC)

S. 270A: Penalty for under-reporting and misreporting of income-Deductions claimed under binding High Court precedent subsequently overruled-Bona fide explanation and full disclosure-Assessed income not exceeding processed income-Penalty unsustainable-Ad-interim stay granted.[S. 270A(2), 270A(6), 264, Art. 226]

GM Modular (P.) Ltd. v. PCIT [2026] 309 Taxman 365 (Bom)(HC)

S. 264 : Commissioner-Revision of other orders-Condonation of delay-Revision filed nearly seven years after rejection of the rectification application uploaded on the portal-Institutional assessee expected to be diligent-No sufficient cause-Revision rightly rejected. [S. 10(25), 154, Art. 226]

Tata Project Provident Fund Trust v. PCIT (2026) 309 Taxman 315 (Telangana)(HC)

S. 264: Commissioner-Revision of other orders-Exemption under section 11 denied due to inadvertent and bona fide punching errors in the return processed under section 143(1)-Assessee has the discretion to seek revision instead of appeal-Commissioner obliged to consider and grant relief even for an error committed by the assessee itself. [S. 11, 143(1), 154, 246A, Art. 226]

Swaminarayan Mandir Trust v. CIT (E) (2026) 488 ITR 65 / 309 Taxman 159 (Bom.)(HC)