Case Details: Chaya vs. State of Maharashtra - [2026] 184 taxmann.com 530 (SC)

Judiciary and Counsel Details

• Alok Aradhe & Pamidighantam Sri Narasimha, JJ.

Facts of the Case

In the instant case, the National Council for Teacher Education (NCTE) issued guidelines for conducting the Teacher Eligibility Test (TET). The said Guidelines prescribe qualifying marks for passing TET. The Qualifying marks for passing TET for candidates belonging to the general categories were fixed at 60%.

However, State Government, Local Bodies, Government-aided and unaided institutions were granted liberty to grant concessions to persons belonging to Scheduled Castes, Scheduled Tribes, Other Backward Classes and differently abled persons, etc., in accordance with the extant reservation policy. Thus, relaxation in TET marks is expressly permitted by NCTE.

It was noted that the relaxation in one of the conditions for securing 60% marks in the qualifying examination, i.e., TET, only enables reserved category candidates to participate in the main examination, i.e., TAIT. Such relaxation only creates a level playing field. Further, it was noted that inter se merit for appointment has to be determined solely based on performance in the main examination, i.e., TAIT.

Supreme Court Held

The Supreme Court observed that no relaxation or concession has been granted to reserved category candidates in the main examination, i.e. TAIT, and their merit has been evaluated at par with general category candidates.

The Supreme Court held that appellants who admittedly were more meritorious than the last selected candidate under the general category could not be excluded from consideration under the general category in the absence of any express prohibition in the Recruitment Rules/notification.

Further, the Supreme Court held that the relaxation in the qualifying criteria affects only eligibility, not merit, and that migration is permissible in the absence of any prohibition. Therefore, the appellants were entitled to migrate to the general category.

List of Cases Reviewed

• Order of High Court of Judicature at Bombay, Bench at Aurangabad in WPC-2534-2024, dated 14.02.2025 (para 33) set aside
• Jitendra Kumar Singh v. State of U.P. (2010) 3 SCC 119
• Vikas Sankhala v. Vikas Kumar Agarwa (2017) 1 SCC 350 (para 32) followed
• Government of (NCT of Delhi) v. Pradeep Kumar (2019) 10 SCC 120 (para 30)
• Union of India v. Sajib Roy [2025] 178 taxmann.com 275 (SC)/2025 SCC OnLine SC 1943
• Union of India v. G. Kiran [2026] 182 taxmann.com 157 (SC)/2026 INSC 15 (para 32) distinguished

List of Cases Referred to

• Government of (NCT of Delhi) v. Pradeep Kumar (2019) 10 SCC 120 (para 9)
• Jitendra Kumar Singh v. State of U.P. (2010) 3 SCC 119 (para 10)
• Vikas Sankhala v. Vikas Kumar Agarwa (2017) 1 SCC 350 (para 10)
• Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra 2025 SCC OnLine SC 1912 (para 10)
• Saurav Yadav v. State of U.P. (2021) 4 SCC 542 (para 10)
• Indra Sawhney v. Union of India (1992) Supp (3) SCC 217 (para 10)
• Rajasthan High Court v. Rajat Yadav [2025] 181 taxmann.com 906 (SC) (para 10)
• Tej Prakash Pathak v. Rajasthan High Court (2025) 2 SCC 1 (para 10)
• V. Lavanya v. State of T.N. (2017) 1 SCC 322 (para 10)
• Union of India v. Sajib Roy [2025] 178 taxmann.com 275 (SC) (para 16)
• Pramati Educational & Cultural Trust v. Union of India (2014) 8 SCC 1 (para 17)
• Union of India v. G. Kiran [2026] 182 taxmann.com 157 (SC) (para 18).

The post TET Relaxation Affects Eligibility Not Merit – General Category Migration Allowed | SC appeared first on Taxmann Blog.

source

1. Introduction

In a globalised business environment, procurement of inventory in foreign currency is no longer exceptional but routine. Yet, the accounting treatment of foreign exchange differences arising on such purchases remains a persistent area of confusion for preparers of financial statements. The difficulty does not lie in the mechanics of recording a foreign currency transaction, but in correctly interpreting the interaction between Ind AS 2 and Ind AS 21, and, in certain situations, Ind AS 23. Misapplication in this area can materially affect inventory valuation, reported profits, and key financial ratios.

At the heart of the issue is a deceptively simple question: when exchange rates fluctuate between the date of purchase and the date of payment, should the resulting differences be treated as part of the cost of inventory or recognised in profit or loss? The answer requires a clear understanding of the conceptual boundaries set by the standards.

Let us understand the query with the help of some case scenario and relevant provision of Ind AS 2 and Ind AS 21.

2. Case Scenario

Alpha Private Limited, an Indian manufacturing company, imports raw materials from a US supplier. On 1st January 2025, the company purchases inventory worth USD 10,000 on 90-day credit terms when the exchange rate is ₹80 per USD. At the reporting date, 31st March 2025, the exchange rate increases to ₹85 per USD, and the payment is subsequently settled on 30th April 2025 when the exchange rate stands at ₹83 per USD. By the end of the reporting period, 60% of the inventory has been consumed in production, while the remaining 40% is held as closing inventory.

The above transaction requires determination of the appropriate accounting treatment in the books of Alpha Private Limited, including the amount at which inventory should be initially recognised, the value at which closing inventory should be carried as at 31 March 2025, and the treatment of foreign exchange differences arising between the date of purchase and the date of settlement.

3. Relevant Provisions

3.1 Ind AS 2 – Inventories

Para 9 of Ind AS 2

Inventories shall be measured at the lower of cost and net realisable value.

Para 10 of Ind AS 2

The cost of inventories shall comprise all costs of purchase, costs of conversion and other costs incurred in bringing the inventories to their present location and condition.

3.2 Para 11 of Ind AS 2

The costs of purchase of inventories comprise the purchase price, import duties and other taxes (other than those subsequently recoverable by the entity from the taxing authorities), and transport, handling and other costs directly attributable to the acquisition of finished goods, materials and services.

3.3 Ind AS 21 – The Effects of Changes in Foreign Exchange Rates

Para 8 of Ind AS 21

Monetary items are units of currency held and assets and liabilities to be received or paid in a fixed or determinable number of units of currency.

Para 21 of Ind AS 21

A foreign currency transaction shall be recorded, on initial recognition in the functional currency, by applying to the foreign currency amount the spot exchange rate between the functional currency and the foreign currency at the date of the transaction.

Para 23 of Ind AS 21

At the end of each reporting period:

(a) foreign currency monetary items shall be translated using the closing rate

(b) non-monetary items that are measured in terms of historical cost in a foreign currency shall be translated using the exchange rate at the date of the transaction

(c) non-monetary items that are measured at fair value in a foreign currency shall be translated using the exchange rates at the date when the fair value was measured.

Para 28 of Ind AS 21

Exchange differences arising on the settlement of monetary items or on translating monetary items at rates different from those at which they were translated on initial recognition during the period or in previous financial statements shall be recognised in profit or loss in the period in which they arise.

4. Analysis

This case highlights several important conceptual and practical aspects of accounting for foreign exchange differences.

First, the inventory is initially recognised at the transaction date rate in accordance with Ind AS 21 and Ind AS 2. This establishes the historical cost of inventory, which becomes the basis for both consumption and closing stock valuation.

Second, the subsequent exchange fluctuation does not affect the carrying amount of inventory. This is because inventory is a non-monetary item as per Ind AS 21, and Ind AS 2 does not permit inclusion of costs that do not contribute to bringing the inventory to its present location and condition. The closing inventory continues to be measured at Rs. 3,20,000, (Rs. 10,000*80*40%) unaffected by the change in exchange rates.

Third, the entire exchange difference of Rs. 50,000 [(85-80)*10,000] at year-end and the subsequent gain of Rs. 20,000 on settlement are recognised in profit or loss in accordance with Ind AS 21. These differences arise due to the re-measurement of a monetary liability and not due to any change in the underlying inventory.

A particularly important insight from this case is that even though a portion of the inventory remains unsold at the reporting date, no part of the exchange loss is allocated to closing inventory. Attempting to do so would effectively revalue a non-monetary asset using closing rates, which is inconsistent with Ind AS 21.

Further, if an entity were to capitalise the exchange loss into inventory, the closing stock would increase, leading to an artificial increase in profits. Such treatment would violate Ind AS 2 and Ind AS 21.

The case also demonstrates that exchange differences are independent of whether the inventory is consumed or remains in stock. Conceptually, the exchange loss of Rs. 50,000 recognised at year-end and the subsequent gain of Rs. 20,000 upon settlement do not represent costs incurred to bring the inventory to its present condition. Instead, they arise due to the timing of payment and currency fluctuations, which are financing effects. Consequently, including such differences in inventory cost would violate the principles of Ind AS 2.

Click Here To Read The Full Story

The post Ind AS Treatment of Forex Differences on Inventory Purchases appeared first on Taxmann Blog.

source

Case Details: Sanjay Kumar Bijay Kumar vs. Principal Commissioner of Income-tax-I - [2026] 184 taxmann.com 475 (Orissa)

Judiciary and Counsel Details

• Harish Tandon, CJ. & Murahari Sri Raman, J.
• Pranaya Kishore Harichandan & Pragyant Harichandan, Advs. for the Petitioner.
• Subash Chandra Mohanty, Sr. Standing Counsel for the Respondent.

Facts of the Case

The petitioner, a partnership firm, has been carrying on its business dealing in cattle feed and building material on a wholesale and retail basis since 1985-86. It has been furnishing returns under the provisions of the Income Tax Act, 1961, disclosing PAN-2, since Assessment Year 2003-04, but it has never utilised PAN-1 in connection with its business activities. However, due to inadvertence, it disclosed PAN-1 in certain banking transactions with Canara Bank; nonetheless, it requested the Bank to make corrections in its records, listing PAN-2.

On collecting information regarding deposits made with the said Bank, the Deputy Commissioner of Income Tax (DCIT) issued a notice under Section 148 for the assessment of escaped income under Section 147 in respect of PAN-1. Further intimation was also issued in this regard.

The matter reached the Orissa High Court.

High Court Held

The High Court held that the DCIT, while passing an order under Section 148A(3), recorded that the assessee had been filing its returns using PAN AATFS3658P from the Assessment Year 2007-08 onwards. However, the assessee used PAN ABAFS4271L for the bank accounts maintained by it with Canara Bank during the Financial Year 2018-19. It was pertinent to mention that, for a similar ground, the ITO passed an Order under Section 147 read with Section 144, computing the total income of the assessee as nil.

Hence, the reason assigned by the DCIT for initiating the proceeding for assessment was found to be self-contradictory. The DCIT cannot sit over the view expressed on the facts in earlier assessment proceedings on the same subject matter, adjudicated by another quasi-judicial authority. The ITO’s factual narration clearly stated that the assessee had been filing returns using PAN AATFS3658P, but not PAN ABAFS4271L. Thus, the DCIT, while attempting to protect the revenue’s interest, should not be allowed to proceed with the assessment again under Section 147 of the IT Act.

List of Cases Referred to

• CIT v. Chhabil Dass Agarwal [2013] 36 taxmann.com 36 (SC)/[2013] 217 Taxman 143 (SC)/[2013] 357 ITR 357 (SC) (para 5.1)
• Godrej Sara Lee Ltd. v. Excise and Taxation Officer-cum Assessing Authority (2023) 3 SCR 871 (para 5.1)
• Muljibhai Patel v. Nandlal Khodidas Barot AIR 1974 SC 2105 (para 5.2)
• State of Tripura v. Manoranjan Chakraborty (2001) 10 SCC 740 (para 5.3)
• VFPL ASIPL JV Company v. Union of India 2020 (III) ILR-CUT 388 (para 5.4)
• CIT v. Sanjay Kumar Garg [2015] 64 taxmann.com 334 (Delhi) (para 6.14)
• Kamdhenu Enterprises Ltd. v. ITO [2023] 146 taxmann.com 417 (Delhi) (para 6.15)
• Kunjan Nair Sivaraman Nair v. Narayan Nair (2004) 3 SCC 277 (para 6.7)
• CCE, Nagpur v. Shree Baidyanath Ayurved Bhawan Ltd. 2009 taxmann.com 1041 (SC)/[2009] 237 ELT 225 (SC) (para 6.8)
• Neelima Srivastava v. State of Uttar Pradesh [2022] 8 taxmann.com 1547 (SC) (para 7.2)
• Experion Developers Pvt. Ltd. v. Himanshu Dewan and Sonali Dewan (2023) 12 SCR 1118 (para 8.1).

The post Second Reassessment on Same Issue Invalid Once Prior Section 147 Order Attains Finality | HC appeared first on Taxmann Blog.

source

Case Details: Arrhum Tradelink (P.) Ltd. vs. Manoj Khattar - [2026] 184 taxmann.com 415 (NCLT-Ahd.)

Judiciary and Counsel Details

• Mrs Chitra Hankare, Judicial Member & Dr Velamur G Venkata Chalapathy, Technical Member
• Aadit Sanjanwala, Adv. for the Applicant.
• Nipun Singhvi, Mayur Jugtawat, Rahul Bhavsar, Nikunt Raval, Ramchandra Madan, Ishan Agrawal, Tirth Nayak, Advs. & Amar N. Bhatt, Senior Adv. for the Respondent.

Facts of the Case

In the instant case, the CIRP was initiated against the corporate debtor and, as no resolution plan was approved, liquidation was ordered. The Liquidator issued a public sale notice for the sale of the corporate debtor as a going concern and conducted an e-auction in which the applicant emerged as the successful bidder.

The applicant filed an application under Section 60(5) of the IBC, seeking relief and concessions, which was dismissed. On appeal, the NCLAT set aside said order, permitting the applicant to file a fresh application for reliefs and concessions.

The applicant filed the present application under Section 60(5)(c) of the IBC seeking broad reliefs, concessions, relaxations and permissions to enable revival and continued operations of the Corporate Debtor as a going concern, asserting acquisition with absolute title free from past liabilities and seeking clean-slate treatment and securities-law related directions, including on delisting/relisting and an effective date.

NCLT Held

The NCLT held that since corporate debtor had been sold on an ‘as is where is’, ‘as is what is’, ‘whatever there is’ and ‘without recourse’ basis and it seemed that no reliefs and concessions sought by applicant were contemplated in terms and conditions of process document, nor consent or opinion sought before proceeding on sale as going concern under Section 32A from this Tribunal, application filed under Section 60(5)(c) by applicant was not maintainable, even if application was filed also under Regulation 32A of IBBI (LP) Regulations read with Rule 11 of NCLT rules. Therefore, the instant application was to be rejected.

List of Cases Reviewed

• Shantech International (P.) Ltd. v. Devendra Singh CA (AT) (Ins) No. 1520 of 2024 (para 11) followed

List of Cases Referred to

• Embassy Property Developments (P.) Ltd. v. State of Karnataka [2019] 112 taxmann.com 56/[2020] 157 SCL 445 (SC) (para 5)
• Arun Kumar Jagatramka v. Jindal Steel and Power Ltd. [2021] 125 taxmann.com 244/165 SCL 652 (SC) (para 8)
• Shantech International (P.) Ltd. v. Devendra Singh [CA (AT) (Ins) No. 1520 of 2024] (para 11).

The post No Reliefs in Going Concern Sale on ‘As Is Where Is’ Basis | NCLT appeared first on Taxmann Blog.

source

Case Details: Sanjay Construction vs. State of U.P. - [2026] 184 taxmann.com 576 (Allahabad)

Judiciary and Counsel Details

• Shekhar B. Saraf & Manjive Shukla, JJ.
• Deepak Kumar Pandey, Piyush Agnihotri & Shailesh Sachan for the Petitioner.

Facts of the Case

The petitioner filed a writ petition challenging the adjudication order passed under whereby tax, interest, and penalty were imposed pursuant to a show cause notice (SCN). It was submitted that although the show cause notice proposed demand of tax, interest, and penalty, it failed to quantify the interest liability despite the relevant period being known at the time of issuance. It was contended that such non-quantification of interest in the SCN was in violation of Section 75(7) of the CGST Act and rendered the entire proceedings invalid. It was further contended that reliance on Section 75(9) to cure such defect was misplaced, as the said provision pertains to non-quantification in the adjudication order and not in the SCN. The matter was accordingly placed before High Court.

High Court Held

The High Court held that Section 75(7) of the CGST Act mandates proper specification of demand in the SCN, including quantification of interest where the liability pertains to a known period. It observed that in the present case, the interest was ascertainable at the time of issuance of the SCN, and therefore, failure to quantify the same constituted a clear statutory violation. The Court further held that Section 75(9) could not be invoked to cure defects in the SCN, as it applies only to non-quantification in the adjudication order and not at the stage of initiation of proceedings. Accordingly, the impugned show cause notice and the consequent adjudication order were held invalid and quashed.

List of Cases Referred to

• Vrinda Automation v. State of Uttar Pradesh [2025] 175 taxmann.com 826/111 GST 254/99 GSTL 411 (Allahabad) (para 7).

The post SCN Without Interest Quantification Invalid Under Section 75(7) | HC appeared first on Taxmann Blog.

source

The National Financial Reporting Authority (NFRA), under its mandate prescribed in Section 132 of the Companies Act, 2013, has issued six new inspection reports on Chartered Accountant firms as part of its audit quality inspection initiative.

Section 132 entrusts NFRA with the responsibility of monitoring compliance with auditing and accounting standards, overseeing the quality of professional services, and recommending measures for improvement. In line with this mandate, NFRA commenced its latest round of audit quality inspections in March 2025, following the procedures laid down in the NFRA Rules, which include evaluation of auditors’ quality control systems and documentation practices.

The primary objective of these inspections is to assess whether audit firms are complying with regulatory and professional requirements and whether their quality control systems are adequate and effective. This includes evaluating the governance framework of firms, the effectiveness of internal controls over audit quality, and the processes for identifying and mitigating audit risks.

The inspection process involves a review of quality control policies, focused examination of key areas, and test checks of both quality control processes and selected audit engagements carried out during the year.

It is important to note that these inspections are intended to identify areas for improvement in audit firms’ quality control systems. They are not designed to provide a comprehensive review of all aspects of a firm’s operations, nor to identify every weakness in audit execution. Similarly, the inspection reports are not meant to serve as ratings or marketing tools, but rather as a mechanism to enhance overall audit quality and professional standards.

Click the link below to access the inspection reports:

Inspection Report 1

Inspection Report 2

Inspection Report 3

Inspection Report 4

Inspection Report 5

Inspection Report 6

Click Here To Read The Full Story

The post NFRA Issues Six Inspection Reports on CA Firms to Strengthen Audit Quality appeared first on Taxmann Blog.

source

Case Details: Sameer Malik vs. Union of India - [2026] 184 taxmann.com 550 (Gauhati)

Judiciary and Counsel Details

• Pranjal Das, J.
• Ms S.K. Nargis, Adv. for the Appellant.
• S.C. Keyal, learned Standing Counsel for the Respondent.

Facts of the Case

The petitioner was subjected to arrest by the Anti-Evasion Unit in connection with an investigation alleging issuance of fake invoices and wrongful availment of Input Tax Credit (ITC) through non-existent firms. Prior to such arrest, a notice under section 35(3) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) was issued requiring the petitioner to appear before the investigating officer at a specified time on the same day. However, the petitioner was arrested before the scheduled time of appearance, and it was contended that such action was taken without recording any reasons for bypassing the statutory procedure prescribed for securing appearance. The petitioner sought bail on the ground that there was non-compliance with the mandatory procedural safeguards, while the investigating officer (IO) admitted that the timing mentioned in the notice was erroneous but failed to justify the premature arrest. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the procedural safeguards embodied under section 35(3) of the BNSS, akin to those under section 41A of the Code of Criminal Procedure, were applicable to arrests made in connection with offences under section 69 read with section 132 of the CGST Act. It was observed that in cases where an arrest is effected without ensuring compliance with the notice procedure, the investigating officer is required to record valid reasons for such deviation. The Court noted that since the arrest was effected prior to the time fixed for appearance on the same day, the notice could not be said to have been effectively complied with, thereby rendering the arrest procedurally defective. In the absence of any justification for such deviation, the arrest was held to be infirm in law. Consequently, the petitioner was held entitled to a grant of bail.

List of Cases Referred to

• Radhika Agarwal v. Union of India [2025] 171 taxmann.com 832/95 GSTL 225 (SC) (para 10)
• Arnesh Kumar v. State of Bihar (2014) 8 SCC 273 (para 11).

The post GST Arrest Invalid for Non-Compliance with BNSS Notice | HC appeared first on Taxmann Blog.

source

RBI/2025-26/252 A.P. (DIR Series) Circular No. 24; Dated: 27.03.2026

1. Regulatory Background

Click Here To Read The Full Circular

The post RBI Caps Offshore INR Positions at $100 Million appeared first on Taxmann Blog.

source

Circular no. RBI/FMRD/2025-26/392 FMRD.MIOD.No.9/11.01.057/2025-26; Dated: 27.03.2026

Click Here To Read The Full Circular

The post RBI Issues RBI (Unique Identifiers in Financial Markets) Directions 2026 appeared first on Taxmann Blog.

source

Case Details: Deputy Commissioner of Income-tax vs. Balar Marketing (P.) Ltd. - [2026] 184 taxmann.com 480 (Delhi-Trib.)

Judiciary and Counsel Details

• Anubhav Sharma, Judicial Member & Manish Aggarwal, Accountant Member
• Rajiv Khandelwal, CA, Jaind Kumar Jaiswal & Gagan R. Khandelwal, Advs. for the Appellant.
• Jitender Singh, CIT-DR for the Respondent.

Facts of the Case

The assessee was a private limited company. A search was conducted at the premises of the assessee company’s administrative head. As a result of the search, two mobile phones were seized. Analysis of digital data extracted from these phones revealed WhatsApp/SMS chats and certain images of one software.

Assessing Officer (AO) examined said images and chats, which allegedly reflected the exchange of cash tokens through a hawala network, and concluded that the assessee had effected cash sales to various parties. He made additions over the years based on such electronic data and statements. The matter reached before the Delhi Tribunal.

ITAT Held

The Delhi Tribunal held that the incriminating material relied upon by the Assessing Officer was not primary evidence, as the original software was neither found nor retrieved from any device. The material consisted solely of images allegedly shared for transaction acknowledgement. Further, WhatsApp chats contained only numerical figures, allegedly treated as coded entries, without independent narration of transactions.

The copy of the 65B certificate, purportedly issued by the administrative head, was merely a certificate of expertise regarding the due process adopted. At the same time, the data was backed up from the impugned devices to devices that were cloned. However, subsequently, as to how data was retrieved, and relevant incriminating evidence was extracted from devices by whom, had not been certified.

Since images on mobile devices constitute secondary evidence, any reliance on them necessitates strict adherence to the Board’s instructions for establishing authenticity. In the present case, the absence of a proper extraction report, a valid certificate under section 65B, and an adequately documented chain of custody rendered the electronic evidence inadmissible. Accordingly, additions made solely based on such unauthenticated material could not be sustained.

List of Cases Reviewed

• Pr. CIT v. Pavitra Realcon (P.) Ltd. [2024] 340 CTR 225 (Delhi)/240 DTR 465 (Delhi)(HC) (para 13.9)
• CIT v. SMC Share Brokers Ltd. [2007] 159 Taxman 306 (Delhi)/[2007] 288 ITR 345 (Delhi) (para 14)
• Dhakeswari Cotton Mills Ltd. v. CIT [1954] 26 ITR 775 (SC) (para 15)
• Pr. CIT v. Smt. Rashmi Rajiv Mehta [2024] 160 taxmann.com 723 (Delhi)/[2024] 299 Taxman 82 (Delhi)/[2025] 474 ITR 97 (Delhi) (para 15.1)
• Dr. Partap Singh v. Director of Enforcement [1985] 22 Taxman 30 (SC)/[1985] 155 ITR 166 (SC) (para 15.2)
• CIT v. Sati Oil Udyog Ltd. [2015] 56 taxmann.com 285 (SC)/[2015] 230 Taxman 521 (SC)/[2015] 372 ITR 746 (SC) (para 17)
• Addl. Director General Adjudication v. Suresh Kumar and Co. Impex Pvt. Ltd. [Civil Appeal Nos. 11339-11342 of 2018, dated 20-8-2025] (para 19) followed
• Pr. CIT v. Shiv Kumar Nayyar [2024] 163 taxmann.com 9 (Delhi)/[2024] 299 Taxman 385 (Delhi)/[2024] 467 ITR 186 (Delhi) (para 50) followed

List of Cases Referred to

• Pr. CIT v. Shiv Kumar Nayyar [2024] 163 taxmann.com 9 (Delhi)/[2024] 299 Taxman 385 (Delhi)/[2024] 467 ITR 186 (Delhi) (para 4)
• Pr. CIT v. Anuj Bansal [2024] 165 taxmann.com 3 (SC)/[2024] 300 Taxman 184 (SC)/[2024] 466 ITR 254 (SC) (para 4)
• ACIT v. Serajuddin & Co. [2023] 150 taxmann.com 146 (Orissa)/[2023] 292 Taxman 566 (Orissa)/[2023] 454 ITR 312 (Orissa) (para 4)
• CIT v. S. Khader Khan Son [2012] 25 taxmann.com 413 (SC)/[2012] 210 Taxman 248 (SC)/[2013] 352 ITR 480 (SC) (para 13.2)
• Pullangode Rubber Produce Co. Ltd. v. State of Kerala [1973] 91 ITR 18 (SC) (para 13.2)
• Pr. CIT v. Pavitra Realcon (P.) Ltd. [2024] 340 CTR 225 (Delhi) (para 13.9)
• CIT v. SMC Share Brokers Ltd. [2007] 159 Taxman 306 (Delhi)/[2007] 288 ITR 345 (Delhi) (para 14)
• C. Vasantlal and Co. v. CIT [1962] 45 ITR 206 (SC) (para 14)
• Dhakeswari Cotton Mills Ltd. v. CIT [1954] 26 ITR 775 (SC) (para 15)
• Umacharan Shaw & Bros. v. CIT [1959] 37 ITR 271 (SC) (para 15)
• Omar Salay Mohamed Sait v. CIT [1959] 37 ITR 151 (SC) (para 15)
• CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 (SC) (para 15)
• Pr. CIT v. Smt. Rashmi Rajiv Mehta [2024] 160 taxmann.com 723 (Delhi)/[2024] 299 Taxman 82 (Delhi)/[2025] 474 ITR 97 (Delhi) (para 15.1)
• Dr. Partap Singh v. Director of Enforcement [1985] 22 Taxman 30 (SC)/[1985] 155 ITR 166 (SC) (para 15.2)
• Chuharmal v. CIT [1988] 38 Taxman 190 (SC)/[1988] 172 ITR 250 (SC) (para 15.2)
• Controller of Estate Duty v. Rameshwar Lal Khetawat [1995] 80 Taxman 597 (Rajasthan)/[1995] 214 ITR 811 (Rajasthan) (para 15.2)
• CIT v. Durga Prasad More [1971] 82 ITR 540 (SC) (para 15.2)
• Sumati Dayal v. CIT [1995] 80 Taxman 89 (SC)/[1995] 214 ITR 801 (SC) (para 15.2)
• CIT v. Sati Oil Udyog Ltd. [2015] 56 taxmann.com 285 (SC)/[2015] 230 Taxman 521 (SC)/[2015] 372 ITR 746 (SC) (para 17)
• Addl. Director General Adjudication v. Suresh Kumar and Co. Impex Pvt. Ltd. [Civil Appeal Nos. 11339-11342 of 2018, dated 20-8-2025] (para 19)
• Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal (2020) 7 SSC 1 (para 19)
• S. Narayanappa v. CIT [1967] 63 ITR 219 (SC) (para 45)
• Rishabchand Bhansali v. Dy. CIT [2004] 136 Taxman 579 (Karnataka)/[2004] 267 ITR 577 (Karnataka) (para 45)
• Home Finders Housing Ltd. v. ITO [2018] 93 taxmann.com 371 (Madras)/[2018] 404 ITR 611 (Madras) (para 45)
• Usha Satish Salvi v. ACIT [IT Appeal Nos. 4239, 4237 & 4238/Mum/2023, dated 23.01.2025] (para 45)
• ACIT v. Serajuddin and Co. [2024] 163 taxmann.com 118 (SC)/[2024] 299 Taxman 448 (SC) (para 49)
• Dheeraj Chaudhary v. Asstt. CIT [2025] 178 taxmann.com 360 (Delhi – Trib.) (TM) (para 51).

The post No Additions Without Valid 65B Certificate | ITAT appeared first on Taxmann Blog.

source