Income Tax - SC Orders / Highlights

❯

❯❯

0 / 200

Expand Note

Add to Folder

No Folders have been created

Are you sure you want to delete "My most important" ?

NOTE:

Open Link

Case Laws

All › Income Tax › Income Tax - SCH

Showing Results for :

Reset Filters

Results Found:

Page of 173

Press 'Enter' after typing page number.

21 to 40 of 3443 Results

Show AI Text Quick Glance by AI Headnote

2026 (9) TMI 270 - SC Order Income Tax

Quick Glance (AI)Headnote

Reassessment sanction requirements and TOLA applicability remained undisturbed as the challenge to the relied-upon ruling failed.
Validity of reassessment reopening under sections 147 and 151 was raised where approval or sanction of the competent authority was alleged to be absent or granted by the wrong authority. The scope of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) and the relevance of issuance of notice within four years were also in issue. The Supreme Court dismissed the special leave petition because the special leave petition against the relied-upon judgment had already been dismissed.

2026 (9) TMI 150 - SC Order Income Tax

Quick Glance (AI)Headnote

Recorded satisfaction in reassessment proceedings remains necessary before initiating penalties for prohibited cash loan or repayment transactions.
Penalty under sections 271D and 271E requires the concerned Assessing Officer to record satisfaction during reassessment proceedings before initiating penalty action. The Supreme Court dismissed the special leave petition both for delay and on merits, thereby confirming the High Court's order on this requirement.

2026 (9) TMI 149 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Transfer-pricing treatment of AMP expenditure remains open after delayed Special Leave Petitions were dismissed without substantive determination.
Special Leave Petitions concerning whether advertisement and market promotion expenditure constituted an international transaction, the use of the bright-line test, TNMM-based benchmarking and segmentation, comparability selection, and protective transfer-pricing adjustments were dismissed because Revenue did not satisfactorily explain substantial filing delays. The question of law on these transfer-pricing issues remained open, so the dismissal did not determine the substantive principles.

2026 (9) TMI 148 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Software royalty under DTAA turns on copyright reproduction rights versus a limited licence to use shrink-wrapped software.
Royalty treatment under a DTAA was raised in relation to payments for computer software supplied under a non-exclusive, non-transferable licence. The issue concerned whether such arrangements confer copyright rights, particularly a right to reproduce the software, or merely permit use of off-the-shelf or shrink-wrapped software. The Special Leave Petition was dismissed because similar Special Leave Petitions had been dismissed.

2026 (8) TMI 1580 - SC Order Income Tax

Quick Glance (AI)Headnote

Limitation for assessment proceedings bars delayed notices, leaving the challenged search-linked action time-barred and quashed.
Proceedings under section 153C for the relevant assessment years were treated as time-barred under the limitation prescribed by the third proviso to section 153B(1), resulting in quashing of the notices and proceedings. The Supreme Court found no ground to interfere with that determination while exercising jurisdiction under Article 136 of the Constitution and dismissed the special leave petition. The limitation finding therefore remained operative for the challenged section 153C proceedings.

2026 (8) TMI 1787 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Compassionate tax policy for stranded Indian seafarers requires consideration of pandemic residential-status relief within four weeks.
CBDT Circular No. 11 of 2020 concerning residential-status consequences for Indian seafarers unable to leave India during the COVID-19 pandemic was challenged, alongside a request for a compassionate tax policy granting exemption where their Indian stay exceeded 182 days in a financial year. The respondents were asked to consider the representations sympathetically, with reference to specified judicial decisions, and to take an appropriate decision within four weeks.

2026 (8) TMI 1198 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Search assessment additions: delayed challenge failed as binding precedent already governed the disputed unexplained-credit issue.
Special leave petition challenging an assessment under search-related provisions and an addition for unexplained credits was dismissed after a 902-day filing delay. The reasons for condonation were held insufficient. The issues were also treated as governed by the Supreme Court's earlier Abhisar Buildwell principle, leading to dismissal on merits. The filing was criticised as unnecessary because the Department itself accepted that the dispute was already covered by binding precedent, thereby adding to judicial pendency.

2026 (8) TMI 1115 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Excessive delay in repeated tax litigation drew Supreme Court criticism for burdening judicial process with a frivolous petition.
The Supreme Court criticised the Department for filing a special leave petition with an excessive delay after an earlier SLP challenging the same impugned order had already been dismissed for delay. The petition was characterised as frivolous and as unnecessarily burdening the Court. The Court urged the Department to exercise greater vigilance and avoid repeatedly filing matters with exorbitant delay. Although the material lists substantive tax issues concerning goodwill depreciation, CSR expenditure, related-unit valuation, captive power, steam transfers, additional claims and consistency, no determination of those issues is set out.

2026 (8) TMI 1197 - SC Order Income Tax

Quick Glance (AI)Headnote

Royalty characterisation of cricket live-feed fees turns on the distinction between copyright and broadcast rights.
Fees received for live transmission or live feeds of cricket matches are characterised as royalty receipts where the service generating the income falls within Explanation 2 to section 9(1)(vi). The central legal distinction concerns copyright and broadcast rights. The Supreme Court dismissed the Special Leave Petition in light of the order in Deputy Director of Income Tax International Taxation v. Shine Satellite Public Company Ltd.

2026 (8) TMI 1114 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Reassessment notice jurisdiction and faceless assessment requirements return to High Courts under the revised reassessment framework.
Reassessment disputes concern the validity of notices, sanction by the specified authority, and whether jurisdictional Assessing Officers may issue notices instead of the prescribed faceless mechanism or competent Faceless Assessment Officers. The issues also cover the effect of subsequent amending legislation on pending reassessment litigation, including the Finance Act 2021 changes to the reassessment framework and insertion of section 147A. The appeals were disposed of under an earlier Supreme Court order and remitted to the respective High Courts for decision in accordance with that order.

2026 (8) TMI 1048 - SC Order Income Tax

Quick Glance (AI)Headnote

Non-resident payment characterisation as royalty leaves Revenue review option contingent on success in related Supreme Court proceedings.
TDS on payments to non-residents was considered where the ITAT found that payments to three non-resident companies were not royalty under the applicable DTAA. The High Court dismissed the Revenue's appeal but allowed the Revenue to seek review or restoration if its review petition concerning Engineering Analysis Centre of Excellence succeeds before the Supreme Court. The Supreme Court disposed of the petition and related pending applications.

2026 (8) TMI 832 - SC Order Income Tax

Quick Glance (AI)Headnote

Tax collection at source on illegal-mining compounding fees left undisturbed after related challenges were already disposed of.
Collection of tax at source under section 206C was considered in relation to compounding fees recovered from persons engaged in illegal mining, transportation or storage of minerals without a lease, licence, or contractual transfer of mining or quarry rights. The issue concerned the scope of the MMDR Act and Rule 71(5) of the Chhattisgarh Minor Mineral Rules, 2015. The Special Leave Petitions were dismissed because the Special Leave Petitions challenging the common judgment had already been disposed of.

2026 (8) TMI 621 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Withdrawal of show cause notice ends dispute over advance ruling proceedings and Assessing Officer jurisdiction.
Withdrawal of the show cause notice rendered the dispute over withdrawal of the advance ruling application, abeyance of departmental proceedings, CBDT Circular compliance, Assessing Officer jurisdiction and Article 226 writ relief academic. The special leave petitions were dismissed because no issue remained for consideration after the notice was withdrawn.

2026 (8) TMI 831 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Revision jurisdiction cannot replace a time-barred revised return for an omitted tolerance-limit claim after self-assessment processing.
Revision jurisdiction cannot be used to introduce a tolerance-limit claim omitted from a self-assessment return once the statutory period for filing a revised return has expired. Where the return was processed and demand raised on the basis of the taxpayer's self-assessment, remand for fresh consideration of that omitted claim is impermissible. A revision application cannot operate as a substitute for a time-barred revised return.

2026 (8) TMI 488 - SC Order Income Tax

Quick Glance (AI)Headnote

Valuation after book rejection requires State PWD rates over CPWD rates; the High Court view remained undisturbed.
Reliance on a District Valuation Officer's report following rejection of books of account is discussed in relation to the appropriate valuation benchmark. The Commissioner of Income Tax (Appeals) faulted the valuation method used by the District Valuation Officer, while not questioning the procedure of obtaining the valuation report. The text states that valuation should be based on State PWD rates rather than CPWD rates and records dismissal of the Special Leave Petition without interference with the High Court judgment.

2026 (8) TMI 487 - SC Order Income Tax

Quick Glance (AI)Headnote

Provision for discount deductibility remains legally open after the special leave petition was not entertained.
A special leave petition concerning the allowability of a provision for discount as an expense was not entertained by the SC in view of the peculiar facts and circumstances. The petition was dismissed, while any question of law was expressly kept open. The text does not state a binding determination on whether such discount provisions are allowable deductions.

2026 (8) TMI 399 - SC Order Income Tax

AI TextQuick Glance (AI)Headnote

Section 80P deduction for Regional Rural Banks remains governed by the High Court order, with legal questions left open.
The Supreme Court declined to interfere with the High Court order concerning the availability of deduction under section 80P to Regional Rural Banks as co-operative societies, including the statutory deeming fiction under the Regional Rural Banks Act. The Special Leave Petition was dismissed, while any questions of law were expressly kept open.

2026 (8) TMI 398 - SC Order Income Tax

Quick Glance (AI)Headnote

Cloud computing payment characterisation as royalty or technical-service fees remains governed by the undisturbed High Court ruling.
The Supreme Court declined to interfere with the High Court's judgment concerning tax treatment of payments received by a US tax resident for cloud computing services from Indian entities. The dispute concerned whether the payments constituted royalty or fees for technical services under domestic tax law and the India-US DTAA, including issues relating to equipment use, non-exclusive licences, the "make available" condition and withholding tax. The Supreme Court dismissed the Special Leave Petitions, leaving the High Court's judgment undisturbed.

2026 (8) TMI 294 - SC Order Income Tax

Quick Glance (AI)Headnote

TDS on External Development Charges follows the earlier Supreme Court approach, with the special leave petition dismissed.
TDS on External Development Charges received by HUDA from private persons or builders was addressed under sections 194C and 194I. Where tax had not been deducted on those charges, the Supreme Court dismissed the special leave petition by following its earlier order in DLF Homes Panchkula Pvt. Ltd. The dismissal leaves the earlier approach governing TDS treatment of such External Development Charges applicable to the parties.

2026 (8) TMI 214 - SC Order Income Tax

Quick Glance (AI)Headnote

Non-adjudication of appellate grounds cannot support recall when the Tribunal had already considered and rejected them.
Non-adjudication of appellate grounds does not justify recall where the Tribunal has already considered and rejected those grounds. The High Court found that the allegedly undecided grounds had been addressed, leaving no basis to interfere with the appellate order. The Supreme Court dismissed the appeal on that basis.

Page of 173

Press 'Enter' after typing page number.

21 to 40 of 3443 Results

Case Laws

All › Income Tax › Income Tax - SCH

All Case Laws

Showing Results for :

Reset Filters

Page of 173

Press 'Enter' after typing page number.

21 to 40 of 3443 Results

No Records Found

Case Laws

All Case Laws

Topics

Acts Income Tax

➔Previous Next ➔

Contact Us At :

FAQs :

Most Asked Video Tutorials :

Submit Feedback/Suggestion :

Case Laws

Case Laws

Topics