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. 237 : Refunds-Interest on refund-Department directed to process claim for refund with interest under section 244A with interest in accordance with law [S.244A, Art. 226]

NMDC Energy PJSC (Erstwhile National Petroleum Construction Company) v. Dy. CIT (2025) 479 ITR 158/179 taxmann.com 63 (Delhi)(HC)

S. 226 : Collection and recovery-Modes of recovery-Stay-Ex parte assessment order-Pending appeal before Commissioner (Appeals)-High pitched assessment-Assessing Officer directed to pay 20 per cent. deposit of demand-Principal Commissioner directed to deposit Rs. 5 lakhs per month-Attachment of bank account and property-On writ monthly instalment of deposit reduced to Rs. 1 lakh considering hardship caused to assessee Directions to decide appeal before Commissioner (Appeals) expeditiously Coercive proceedings for recovery of demand restrained.[S. 144, 144B, 156, 220(6), 250, Art. 226]

Bali Nagwanshi v. UOI (2025) 479 ITR 681/177 taxmann.com 660 (Chhattisgarh)(HC)

S. 220 : Collection and recovery-Assessee deemed in default-High pitch assessment-Recovery of Rejection of application for stay of demand Precondition of depositing 20 per cent. of demand-Stay of recovery in interim order of court until disposal of pending appeal before Commissioner (Appeals)-Direction to appellate authority to expedite disposal of appeal Interim relief granted to continue until outcome of order in statutory appeal [S. 147, 220(6), 250, Art. 226]

Shyam Oil Extractions Pvt. Ltd. v. PCIT (2025) 479 ITR 677 (Chhattisgarh)(HC)

S. 206C : Collection at source-Trading-Forest produce-Coal sales-Public sector undertaking-Verification of form 27C declaration under section 206C(1A)-Assessee in default-Order of Tribunal quashing the order is affirmed. [S.206C(IA), 260A, Form 27C]

Dy.CIT (TDS) v. Central Coalfields Ltd(2025) 479 ITR 510 /304 Taxman 217 (Jharkhand)(HC)

S. 197 : Deduction at source-Certificate for lower rate-Capital or revenue-Employee stock option-One-time compensation received for surrendering of stocks received under stock option scheme of employer-Stock option not perquisite-Order rejecting application quashed and set aside-Cost of acquisition of stock options cannot be determined Capital receipt not chargeable under section 45-Not chargeable under any other head Charging section and computation section constituted an integrated code-Application for nil deduction rejected by Principal Chief Commissioner-No adequate alternate remedy of appeal-Writ petition maintainable-Order rejecting the application was quashed and set aside. [S. 4, 5, 17(2),45, 48, Art.226]

Manjeet Singh Chawla v. Dy. CIT (2025) 479 ITR 1/ 175 taxmann.com 778 /347 CTR 566 / 256 DTR 33 (Karn)(HC)

S. 153A : Assessment-Search-No incriminating material discovered during search-Principle of finality in tax proceedings-Reassessment, revision-Multiple proceedings on same issue-Order of Tribunal affirmed.[S. 54F, 143(3), 147, 148, 153A, 260A, 263.]

PCIT v. Sasikala Raghupathy (2025) 479 ITR 187 (Mad)(HC)

S. 151A: Face less assessment scheme-Jurisdiction-Search cases Central charge-Under faceless mechanism-e-Assessment of Income Escaping Assessment Scheme, 2022 dated 29-3-20221-Central Board of Direct Taxes order dated 6-9-2021-Judicial propriety-High Court-Precedent-Proper for Bench of court to follow its own authoritative ruling in preference to that of another court.[S. 144B(2), 148, 153A, 153B, 153D [Art. 226]

Kings Pride Infra Projects Pvt. Ltd. v. Dy. CIT (2025) 479 ITR 651 /176 taxmann.com 704 (Telengana) (HC)

S. 151A: Face less assessment scheme-Jurisdiction-Procedure adopted by Department in contravention of statutorily prescribed provisions-Notice set aside-Revenue granted liberty to proceed in accordance with law. [S. 147, 148, Art. 226]

Om Satya Overseas v. UOI (2025) 479 ITR 430 /178 taxmann.com 137 (P & H)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Shares issued less than fair market value-Revision proceedings dropped-Change of opinion-Reassessment notice and proceedings quashed and set aside. [S.56, 147, 148, 148A(b) 148A(d), 263, Art. 226]

Chandra Global Finance Ltd v. ITO [2024] 168 taxmann.com 182/ (2025) 479 ITR 502 (Delhi)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-UOI v. Rajeev Bansal (2024) 469 ITR 46 (SC)-Order and notices not in accordance with amended procedure under Finance Act, 20212 and barred by limitation.[S. 147, 148, 148A(b),148A (d), 149-Finance Act, 2021 Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, Art. 226]

Jay Jay Agro Industries v. ITO (2025) 479 ITR 407 (P & H)(HC)