The Income Tax Appellate Tribunal, Lucknow Bench, partly allowed the appeal of Rohit Real Estates Pvt Ltd for AY 2017-18. The core issue was the disallowance under Section 14A read with Rule 8D. The Tribunal, relying on binding precedents, held that the disallowance cannot exceed the exempt income of Rs.31,070/-. The AO was directed to recompute the disallowance accordingly. The appeal was partly allowed.

In this landmark 1948 Madras High Court judgment, the Court clarified the scope of ‘agricultural income’ under the Income Tax Act 1922 regarding grazing fees. The assessee, a landlord, received income from letting village lands for grazing. The Revenue contended this was taxable as non-agricultural income. The Court, after examining multiple precedents, established that pasturing cattle constitutes an agricultural purpose when the cattle are used for agricultural pursuits. The Court distinguished this from mere sale of grass and emphasized the agricultural nexus of grazing in village contexts. This judgment significantly expanded the interpretation of agricultural income to include ancillary agricultural activities like pasturing, providing important guidance for assessing income from land use.

In Padmalochanan Radhakrishnan vs. Union of India, the Calcutta High Court quashed orders rejecting the petitioner’s claim for carry forward of loss due to a 7-day delay in filing the return. The court held that the Assessing Officer misapplied CBDT Circular No. 11 of 2024 and that the delay was bonafide and negligible. The court directed condonation of delay and processing of the return, following the precedent in Regan Powertech and the principle of proportionality.

In this landmark ruling, the Mumbai ITAT dismissed the Revenue’s appeal, upholding the CIT(A)’s decision to allow deduction under section 80IA and additional depreciation on windmills. The Tribunal clarified that under section 80IA, losses prior to the initial assessment year, if already set off, cannot be notionally carried forward, reinforcing the assessee’s option to choose the initial year. For additional depreciation, it affirmed that eligibility extends to any manufacturing assessee, with no requirement for the new machinery to relate to existing products. This judgment provides critical guidance on infrastructure deductions and depreciation claims, emphasizing statutory interpretation and judicial consistency.

In this landmark transfer pricing and expenditure allowance judgment, the Bombay High Court comprehensively dismissed the Revenue’s appeal, reinforcing key principles: (1) Transfer pricing adjustments must account for qualitative differences under Rule 10B; (2) Retainer-based service agreements have value even if services aren’t fully utilized; (3) Share buyback expenses are revenue expenditures when they don’t create enduring assets; (4) Business expenditure under Section 37 requires only ‘wholly and exclusively’ purpose, not demonstrated benefit. The decision strengthens taxpayer positions on ALP methodologies and expenditure deductibility while curtailing Revenue’s attempts to revisit factual determinations.

In this landmark judgment, the Calcutta High Court clarified the tax treatment of compensation from acquisition of agricultural lands under the Income Tax Act, 1922. The Court ruled that agricultural land does not transform into a capital asset merely due to requisition or non-use by the owner, provided it remains used for agriculture by others. Key principles established include: the expansive interpretation of ‘held’ to encompass constructive possession, the focus on land’s agricultural character at the time of transfer, and the irrelevance of the assessee’s direct income derivation in the relevant year if the land is agriculturally productive. This decision reinforces the exemption of agricultural land from capital gains tax, emphasizing substance over form in determining land use.

In a landmark ruling on TDS applicability, the Delhi High Court has held that landing and parking charges paid by international airlines for using airport infrastructure qualify as ‘rent’ under Section 194-I of the Income Tax Act, 1961. The judgment reinforces the doctrine of strict interpretation in tax law, dismissing equitable considerations and focusing solely on the statutory definition. This decision clarifies that any payment for land use, regardless of terminology, triggers TDS obligations, impacting airline operations and airport fee structures.

In this landmark ruling, the Hyderabad Bench of the Income Tax Appellate Tribunal reinforced a critical principle in Indian tax jurisprudence: disallowance under Section 14A read with Rule 8D is impermissible in the absence of actual exempt income. The Tribunal dismissed the Revenue’s appeals, upholding the CIT(A)’s deletion of disallowances totaling over ₹10.33 crore for AYs 2014-15 and 2016-17. The decision underscores that statutory provisions must be interpreted purposively, and administrative circulars cannot override judicial precedents. This judgment provides clarity for taxpayers engaged in investment activities, affirming that compliance with Section 14A is triggered only upon realization of exempt income, not merely by holding investments.