1) SC: Issues notice on admissibility of assessee’s delayed cross-objections in revenue appeals. SC issued notice in a case where the HC admitted Revenue's appeals on certain substantial questions of law but declined to condone the delay in filing cross-objections by the assessee (filed 461 days late). SC is now seeking Revenue’s opinion if it has any objection on considering assessee's cross-objections by the HC, given that the Revenue’s appeals were admitted on substantial legal grounds.

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2) SC: Affirms HC decision quashing CBDT's search proceedings and consequential actions under section 132(1). SC dismisses the Revenue's Special Leave Petition (SLP), upholding the Bombay HC decision to quash the CBDT-authorized search under Section 132(1), citing that the grounds for the search were irrelevant and the reasons recorded amounted to a mere pretence. While the SC chose not to interfere with the HC judgment, it kept the question of law open; HC observed that the reasons recorded in the file were extremely general in nature (and not disclosed), and that the satisfaction note did not reflect any process of forming a reasonable belief……….. 

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3) HC: Admits UK tax resident appeal despite being a non-filer, to address key issues on reclassification of Income as FTS. HC has admitted an appeal by a UK tax resident against the ITAT order, wherein it was held that the Assessee, providing technical services and receiving payments sourced from India, is liable to tax under Section 9(1)(vii) of the Income Tax Act. Despite the Revenue's objection that the appeal is invalid due to the Assessee’s failure to file a return (and the Income Tax Act’s stipulation that a non-filer cannot maintain an appeal), the HC disagreed. The Court ruled that an appeal can be filed under Section 260A of the Income Tax Act if it raises a substantial question of law, irrespective of the Assessee's filing status. The Assessee has raised several legal questions, with the Court focusing on two issues: 1) whether the Appellant's income of Rs. 3.31 crore is taxable under Indian law or the India-UK Double Taxation Avoidance Agreement (DTAA), and 2) whether the ITAT was correct in reclassifying the income as Fees for Technical Services. The next hearing is scheduled for May 13, 2025. 

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4) HC: Interest on delayed compensation forms part of Capital Gains; Section 56 inapplicable unless clearly separated. HC allowed the assessee’s appeal for Assessment Year (AY) 2015–16 and ruled that compensation received for compulsory land acquisition—including interest on delayed payments under Sections 28 and 34 of the Land Acquisition Act, 1894 (LAA)—is to be treated as capital gains under the Income Tax Act (I.T. Act). In cases involving agricultural land, both the compensation and the interest form part of the exempt income under Section 10(37). HC clarified that since the interest awarded under Sections 28 and 34 of the LAA is compensatory in nature and forms an integral part of the compensation, it cannot be classified as standard "interest" under Section 2(28A) of the I.T. Act. Consequently, such interest does not fall under the purview of Section 56, including Section 56(2)(viii). The assessee had challenged two orders of the ITAT. The first, dated 30.03.2023, held that 9% interest was exempt as capital gains under Section 10(37), while 15% interest was taxable under Section 56(2)(viii). The second, dated 19.04.2024, ruled that all interest on delayed compensation (post the 2010 amendment to the LAA) is taxable under Section 56(2)(viii) and not exempt under Section 10(37), even where the land acquired was agricultural. The assessee contended that interest awarded under Section 28 of the LAA is ……..

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5. HC: Interest on delayed compensation forms part of Capital Gains; Section 56 inapplicable unless clearly separated. HC allowed the assessee’s appeal for Assessment Year (AY) 2015–16 and ruled that compensation received for compulsory land acquisition—including interest on delayed payments under Sections 28 and 34 of the Land Acquisition Act, 1894 (LAA)—is to be treated as capital gains under the Income Tax Act (I.T. Act). In cases involving agricultural land, both the compensation and the interest form part of the exempt income under Section 10(37). HC clarified that since the interest awarded under Sections 28 and 34 of the LAA is compensatory in nature and forms an integral part of the compensation, it cannot be classified as standard "interest"……..

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6. ITAT: Successor AO cannot reopen case on same grounds already examined; Reassessment quashed as void. ITAT quashed 23 reassessment orders pertaining to Assessment Years (AYs) 2012–13 and 2013–14, based on a survey conducted on the charitable trust. ITAT held the reassessments to be void ab initio, citing that they were based solely on a change of opinion and lacked any new or tangible material, thereby violating the provisions of Sections 147 and 143(3) of the Income Tax Act. The reassessment proceedings originated from a survey that uncovered unaccounted cash payments related to land acquisitions and college construction. During the course of the survey, trustees admitted to unaccounted payments amounting to Rs. 2.25 crores in AY 2013-14. Taxes were duly paid on this amount, and the original assessments were completed without any further claims or discrepancies. Years later, however, reassessment notices were issued. The Assessing Officer (AO) alleged underreporting of land and construction costs totaling Rs. 4.90 crores across AYs 2012–13 and 2013–14, which were assessed in the hands of individual trustees. The CIT(A) upheld the reassessment proceedings, leading to the current appeals before the ITAT. In the case of Shri S. Aravind’s appeal for AY 2012–13, the assessee contended that the AO had access to the relevant survey material well before the deadline for issuing a scrutiny notice under Section 143(2) but opted not to initiate scrutiny proceedings.……..

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7. ITAT: Allows Section 80P(2)(d) deduction on Interest from Co-op Bank deposits, subject to gross total Income limit. ITAT ruled that a co-operative society earning interest from deposits with a co-operative bank is eligible to claim a deduction under Section 80P(2)(d) of the Income Tax Act, subject to the gross total income limit. The ITAT instructed the Assessing Officer to allow the deduction under Section 80P(2)(d) based on the interest income included in the gross total income. It also clarified that such deductions under Chapter VIA should be limited to the amount of the gross total income.

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