December 2025

In this Supreme Court ruling, the Revenue’s special leave petitions against Bombay High Court judgments were dismissed summarily. The petitions suffered from substantial delays of 422-524 days and were substantively covered by a binding precedent where similar petitions had already been dismissed. This decision reinforces the Supreme Court’s strict approach to condonation of delay in tax appeals and emphasizes the importance of finality in litigation, particularly when the legal issues are already settled by coordinate benches.

In this landmark ruling by the Income Tax Appellate Tribunal, Kolkata, the bench allowed the assessee’s appeal, striking down an addition of Rs. 11,49,425/- made u/s 68 for alleged bogus LTCG. The Tribunal reinforced fundamental principles of natural justice, holding that the AO’s failure to provide documentary evidence and deny cross-examination rendered the assessment order legally untenable. Critically, the decision underscores that revenue authorities cannot base additions on mere suspicion, generalized data, or unsubstantiated allegations—the burden of proof remains squarely on the department. The ruling aligns with judicial precedents requiring concrete evidence over conjectures, offering robust protection to taxpayers against arbitrary assessments. For professionals, this case serves as a vital reference in disputes involving section 68 additions, natural justice violations, and capital gains scrutiny, highlighting the necessity of procedural fairness and evidentiary substantiation.

In this landmark Supreme Court judgment, the Court addressed a contentious issue regarding interest under Section 214 of the Income Tax Act 1961. The dispute centered on whether an assessee was entitled to interest from the date of the original assessment until the completion of a set-aside assessment. The Court highlighted the judicial inconsistency among High Courts and criticized the High Court’s failure to adjudicate the legal question. Relying on the authoritative precedent set in Modi Industries Ltd. vs. CIT, the Court resolved the ambiguity, ruling against the assessee and in favor of the Revenue, thereby providing clarity and uniformity in the application of Section 214.

In this landmark Supreme Court ruling, the bench dismissed the Revenue’s appeal and affirmed the assessee’s entitlement to Section 10AA exemption for SEZ unit profits. The Court applied the doctrine of precedent, relying on the binding Delhi High Court judgment in Amadeus India, which had already settled this legal issue in favor of taxpayers. This decision reinforces judicial consistency and provides clarity for businesses operating in SEZs regarding their tax exemption claims under Section 10AA.

In this landmark Supreme Court judgment, the Revenue’s appeal challenging the deductibility of a provision for gratuity as business expenditure was dismissed. The Court affirmed the Tribunal’s decision in favor of the assessee, Pearey Lal & Sons P. Ltd., by relying on the established precedent in Shree Sajjan Mills Ltd. vs. CIT. This ruling reinforces the principle that properly accounted provisions for employee gratuity are allowable deductions under the Income Tax Act 1961, providing clarity and consistency in the treatment of such business expenses for corporate taxpayers.

In this landmark ruling, the Supreme Court of India clarified a critical procedural distinction in income tax law, reinforcing the principle that finality in tax assessments is context-specific. The Court held that while the quantified amount of a business loss may become final if not contested, the foundational legal characterization of the income source giving rise to that loss remains open to scrutiny in subsequent proceedings. This decision protects the Revenue’s right to ensure that loss carry-forward benefits are only granted for losses arising from eligible sources, preventing taxpayers from insulating incorrect source determinations through procedural finality. The judgment underscores that substantive legal issues regarding the nature of income and allowable deductions cannot be foreclosed merely by the passage of time or the acceptance of a numerical computation.

In this landmark constitutional interpretation case, the Supreme Court of India authoritatively settled the hierarchy between judicial pronouncements and administrative circulars. The Court unequivocally held that the law declared by the Supreme Court under Article 141 of the Constitution represents the supreme law of the land, and departmental circulars issued by the Central Board of Excise and Customs cannot override such judicial pronouncements. The Court clarified that while circulars are binding on revenue authorities in administrative matters, they cannot prevail over Supreme Court decisions when matters are sub judice. This judgment reinforces the supremacy of judicial interpretation over executive understanding of statutory provisions.

In this landmark Supreme Court judgment, the Revenue challenged the allowance of 7-1/2% of net trust income as administrative expenditure under sections 57(i) and 19(1) of the Income Tax Act, 1961. The Court upheld the lower courts’ decisions, emphasizing the factual nature of the expenditure determination and the binding effect of the unreversed Andhra Pradesh High Court precedent. This ruling reinforces judicial consistency in trust administration expense claims and establishes that Revenue’s failure to challenge earlier favorable judgments creates persuasive authority for subsequent periods.