In this landmark judgment, the Supreme Court of India clarified the distinction between business income and capital gains in share transactions. The Court ruled that where a dealer in shares consistently treats shares as stock-in-trade, subsequent sale profits constitute business income, even after a period of non-trading. The Court also held that consideration received in a bulk sale transaction must be assessed from the seller’s perspective – where the seller had no controlling interest, the entire premium represents share price, not payment for control. This decision reinforces the principle that characterization of shares as stock-in-trade depends on consistent treatment and business intent, not mere holding patterns.

In this landmark judgment, the Supreme Court of India reinforced the principle of alternate remedy in writ jurisdiction. The case involved a government employee compulsorily retired after seeking voluntary retirement. The Court overturned a Single Judge’s decision to entertain a second writ petition on the same matter, after a Division Bench had dismissed the first petition for non-exhaustion of remedy before the U.P. Public Services Tribunal. The ruling underscores that High Courts must respect statutory alternate remedies and cannot allow litigants to circumvent earlier judicial orders through successive writ petitions, thereby ensuring judicial discipline and preventing abuse of process.

In this landmark tax dispute, the Supreme Court reinforced strict interpretation of Section 43B, denying deduction for unpaid bottling fees despite bank guarantees, and disallowed depreciation on idle assets of a defunct business unit. The Court remanded the transformer expenditure issue for factual scrutiny, highlighting the judicial preference for substance over form in classifying capital vs. revenue expenses. This ruling underscores the Revenue’s stance on fiscal discipline while ensuring factual fairness in complex asset-related deductions.

In a landmark ruling on club taxation, the Pune ITAT upheld the exemption of Poona Club Ltd.’s rental income from cottage suites under the principle of mutuality. The Tribunal meticulously dissected the mutuality doctrine, rejecting the Revenue’s argument that exclusion of certain member classes from dissolution assets negates the exemption. It affirmed that mutuality hinges on annual surplus distribution and the absence of profit motive in member transactions, not speculative dissolution scenarios. This decision reinforces the tax-exempt status of genuine member clubs, providing clarity on the interpretation of ‘surplus’ and aligning with precedents from Madras and Allahabad High Courts.

In this landmark ruling by the Chandigarh Bench of the Income Tax Appellate Tribunal, the appeal of Namdhari Industrial Traders Pvt. Ltd. was allowed, setting aside the addition of Rs. 45,00,000/- made under section 68 of the Income Tax Act, 1961. The Tribunal meticulously examined the voluminous evidence submitted by the assessee, including corporate documents, financial statements, and confirmations from three investor companies—Simplex Trading & Agencies Ltd., Zinnia Sales Pvt. Ltd., and Daisy Suppliers Pvt. Ltd. It reaffirmed the principle that the initial onus under section 68 is on the assessee to prove the identity, creditworthiness, and genuineness, which was satisfactorily discharged here. The decision underscores the importance of documentary substantiation in share application money cases and aligns with Supreme Court jurisprudence, providing clarity for taxpayers facing similar scrutiny.

In this landmark constitutional tax case, the Supreme Court delved into the interplay between state reorganization laws and the fundamental right to equality under Article 14. The core issue was whether the continued application of a pre-merger agricultural income tax law only to a specific region within a reorganised state constituted unlawful discrimination. The Court established a nuanced precedent: while historical geographical classifications are initially permissible to ensure smooth administrative integration, their longevity must be scrutinized against the yardstick of rational basis. The judgment underscores that proving an Article 14 violation in such contexts requires a comprehensive factual matrix—not merely alleging differential treatment, but demonstrating its arbitrariness by examining the overall fiscal landscape. The remand for factual determination highlights the Court’s commitment to evidence-based adjudication in equality challenges against tax statutes, reinforcing that temporal passage alone does not invalidate a classification; its substantive justification must be evaluated.

In this Supreme Court judgment, the appellants (heirs of the plaintiff) failed to overturn lower court rulings dismissing their suit for declaration of title over a property purchased in 1963 in the defendant’s name. The Court affirmed that the transaction was not benami, as the plaintiff could not prove that the purchase money was supplied by him or that there was an intention for the defendant to hold the property for his benefit. Key evidence included the absence of reconveyance clauses compared to prior transactions and a contemporaneous letter settling accounts. The suit was also barred by limitation, and possession claims were dismissed as title was not proven. The decision reinforces the factual nature of benami determinations and the burden of proof on claimants.

In this landmark judgment, the Karnataka High Court resolves a contentious issue under Indian income tax law regarding the disallowance of interest payments under section 40(b) of the Income Tax Act 1961. The case involves a firm that paid interest on deposits from minor children and Hindu Undivided Families (HUF) of partners, routed through the partners as guardians/kartas. The Court meticulously examines the judicial conflict pre-1984, where some High Courts applied section 40(b) broadly to any payment to partners, while others limited it to payments in the partner capacity. Crucially, the Court rules that Explanations 2 and 3, inserted by the Taxation Laws (Amendment) Act 1984, are clarificatory and apply retrospectively to assessment years prior to 1985-86. This decision affirms that such payments are deductible, as they are not made to partners in their capacity as partners, thereby promoting fairness and reducing tax litigation. The judgment reinforces the principle that statutory explanations can clarify ambiguous provisions retrospectively, aligning with legislative intent to streamline tax procedures.