Chattisgarh High Court: Maa Harsiddhi Infra Developers P. Ltd. v. ACIT The Hon’ble High Court held that the Income Tax Department cannot invoke the limited powers under Section 143(1)(a) of the Income Tax Act to disallow claims involving debatable legal issues, such as delayed deposit of employees’ contributions towards ESI and EPF under Section …

Telangana High Court: Piramal Swasthya Management and Research Institute v. Assistant Commissioner of Income Tax & Anr. The Hon’ble High Court quashed the reassessment proceedings initiated under Sections 148A(d) and 148 of the Income Tax Act, holding that the Revenue cannot reopen an issue that had already been examined and accepted during the original …

Gujarat High Court: Bhavnaben Darshanbhai Patel v. Income Tax Officer The Hon’ble High Court quashed the reassessment notices ruling that the IT Department cannot reopen completed assessments based on vague third-party documents that have no clear link to the person concerned. The case arose after search under section 132 in the cases on B …

GUJARAT HIGH COURT: Virat Alloys Private Limited v. The Assistant Commissioner of Income Tax Circle, Gandhinagar (SCA No. 5039/2024) Background: The petitioner company filed its revised return of income for the A.Y 2015-16 on 09.03.2017 declaring its income of Rs. Nil. A search was carried out in case of M/s World Window Group. It was …

DELHI HIGH COURT: Commissioner of Income Tax, International Taxation-1, New Delhi v. Clifford Chance Pte Ltd (ITA 353/2025) Background: The assessee, a Singapore-based non-resident law firm, filed NIL income returns for AYs 2020-21 and 2021-22. The AO alleged that the assessee had a service Permanent Establishment (“PE”) and a virtual service PE in India under …

KARNATAKA HIGH COURT: Sri. Kewal Chand Jain v. Assistant Commissioner of Income Tax (W.P. No. 30135/2021) Background: The petitioner challenged assessment order u/s 153C r/w Section 144 of the Income-tax Act, 1961. His residential premises were subjected to a search u/s 132, pursuant to which certain documents were seized. Despite search being conducted at his …

Supreme Court: Shital Fibers Ltd. v. Commissioner of Income Tax (and connected cases) Background: In this case, the appellant had claimed deductions under Section 80-HHC (export profits) and Section 80-IA/80-IB (industrial profits). However, the Income Tax Department disallowed these claims, contending that Section 80-IA (9) prohibits availing double benefits on the same profits, a …

Bank of India v. DCIT Background: The assessee, a public sector bank, received ₹12.93 crore from the RBI under the Export Credit (Interest Subsidy) Scheme, 1968, as compensation for offering export credit to borrowers at concessional interest rates. While filing its return for AY 1992–93, the assessee excluded this subsidy from chargeable interest under …

M/s. Prasad Film Laboratories Pvt. Ltd. v. ACIT Background: The appellant made regular payments to its parent company during the course of business, which were treated by the Assessing Officer as deemed dividends under Section 2(22)(e) of the Income Tax Act. The ITAT remanded the matter back to assessees whether accumulated profits existed on …

Deputy Director Jagdalpur Mining Officer v. The DCIT Background: A TDS survey revealed that the State Mining Department had not collected tax collected at source on compounding fees/fines recovered from persons involved in illegal mining and transportation of minerals. The Income Tax Department treated the State as an assessee-in-default under Section 206C(1C) of the …