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“proximate nexus”

Judicial DoctrinesReopening / 147Reopening / 147134 judgments

THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 1821/BANG/2025[2022-23]Status: DisposedITAT Bangalore09 Apr 2026AY 2022-23

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

For Appellant: Shri Bhardwaj Sheshadri, Advocate &For Respondent: Shri Subramanian, JCIT (DR)
Section 250Section 56Section 80PSection 80P(2)(a)

unsubstantiated receipts cannot be presumed to be attributable to the business of providing credit facilities. In the absence of any material to establish a proximate nexus, the same cannot be brought within the ambit of section 80P(2)(a)(i) of the Act. Accordingly, we hold that the miscellaneous receipts

DCIT CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. CRYSTAL CERAMIC INDUSTRIES LIMITED, AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 860/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. CRYSTAL CERAMIC INDUSTRIES LIMITED, AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 859/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

CRYSTAL CERAMICS INDUSTRIES LIMITED,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

In the result, the appeals filed by the Revenue in ITA Nos

ITA 682/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

under sections 80IC, 80IE, and 10AA of the Act, it is essential to confine the computation to those expenses which have a direct and proximate nexus with the operations of the eligible undertaking. Any attempt to allocate general or common expenses that are not specifically relatable to the activities

VALLABHBHAI DUDABHAI CHHATRALA,SURAT vs. ITO, WARD-3(3) (1), SURAT

In the result, the grounds of appeal raised by the assessee is allowed

ITA 815/SRT/2025[2011-12]Status: DisposedITAT Surat17 Feb 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblevallabhbhai Dudabhai Chhatrala, The Income Tax Officer, Vs. 6, Prabhu Darshan Soc. Nr. Ward-3(3)(5), Dhameliya Nagar, Current Jurisdiction, Varacha Road, Ward-3(3)(1), Rajhans Point, Surat-395006. Surat-395006. [Pan : Aeepc8550 M] (Appellant) .. (Respondent) Appellant By : Shri Mehul Shah, Ar Respondent By: Shri Ajay Uke, Sr. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 17.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri Ajay Uke, Sr. DR
Section 147Section 148Section 250Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT Ms SUCHITRA KAMBLE, JUDICIAL MEMBER

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LIMITED,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

ITA 3243/PUN/2025[2020-21]Status: DisposedITAT Pune16 Feb 2026AY 2020-21

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

attributable to the business of providing credit facilities to members. The appellant has not brought any material on record to establish a direct and proximate nexus between the impugned interest and its lending activity. The Assessing Officer has therefore correctly added Rs.5

VEERACHARYA BABASAHEB KUCHNURE ZILLA NAGARI SAHAKARI PAT SANSTHA LTD.,SANGLI vs. INCOME TAX OFFICER 1(1), SANGLI

In the result, the appeal of the assessee is allowed

ITA 3242/PUN/2025[2018-19]Status: DisposedITAT Pune16 Feb 2026AY 2018-19

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

attributable to the business of providing credit facilities to members. The appellant has not brought any material on record to establish a direct and proximate nexus between the impugned interest and its lending activity. The Assessing Officer has therefore correctly added Rs.5

ZENSAR TECHNOLOGIES LIMITED,MUMBAI vs. DCIT CIRCLE 2(3)(1), MUMBAI

In the result, appeal is allowed

ITA 3439/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Feb 2026AY 2020-21
Section 10ASection 115JSection 142(1)Section 263Section 80GSection 80J

such R&D or\ntransfer it to a third party. Thus, he submitted, when the R&D expenses do\nnot have any direct or proximate nexus to the eligible undertakings no\nallocation of such expenses could have been made. Drawing our attention\nto the documents furnished in the paper book

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21
For Appellant: \nShri Ashwani Taneja, AdvocateFor Respondent: \nMs. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance\" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance\" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

term finance\" under Section 36(1)(viii). A restrictive reading\nthat limits the deduction only to interest income would be in\nignorance of this proximate nexus and result in defeat of the\nlegislative intent of incentivizing long-term financing for\ninfrastructural development.\n2.8.2 It is also a settled law that

IRULA SNAKE CATCHERS INDUSTRIAL CO-OP. SOCIETY LTD.,CHENNAI vs. ITO, WARD-22(1), CHENNAI

In the result, the appeal filed by the assessee is allowed, and

ITA 1790/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Feb 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं. (Ita No.1790/Chny/2025 "नधा"रणवष"/Assessment Years: 2020-21 Irula Snake Catchers Industrial Co- V. Income Tax Officer, Operative Society Ltd, Non-Coporate Ward 22(1), Mahabalipuram Road, Tambaram Vadanemmli Village, Perur Post, Chennai-603 104 [Pan:Aaaai 7894 M] (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Mr. G Baskar, Advocate &For Respondent: Mr. Gouthami Manivasagam
Section 80PSection 80P(2)(a)

used by the legislature is of wider amplitude than the expression “derived from” and covers not only direct income but also income having a proximate nexus with the eligible activity. 11. In the present case, it is an admitted position that: the funds deposited in the savings bank account

ELARA CAPITAL INDIA PRIVATE LIMITED ,MUMBAI vs. ACIT CIRCLE 6(2)(2), MUMBAI

In the result, the appeal filed by the assessee is allowed

ITA 7773/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 14ASection 14A(2)

annual average of monthly investments. The Assessing Officer has neither recorded any objective satisfaction as mandated under section 14A(2) nor demonstrated any proximate nexus between the alleged expenditure and any income not forming part of total income. The learned Commissioner (Appeals) confirmed the said disallowance primarily by placing reliance

DY COMMISSIONER OF INCOME TAX, MUMBAI vs. HITESH SHANTILAL MEHTA, MUMBAI

In the result, the appeal filed by the Revenue is dismissed

ITA 7865/MUM/2025[2005-06]Status: DisposedITAT Mumbai09 Feb 2026AY 2005-06

Bench: adverting to the merits, it is necessary to record that Ground No. 1 raised in the cross-objection was expressly stated to be not pressed by the learned counsel for the assessee at the time of hearing. Accordingly, Ground No. 1 of the cross-objection is dismissed as not pressed. The adjudication hereinafter is, therefore, confined exclusively to Ground No. 2 of the cross- objection, which pertains to the allowability of interest expenditure under section 57 of the Act. 4. Briefly stated, th

Section 143(3)Section 57

require that the expenditure must be incurred solely or exclusively for earning a particular item of income. What is required is a real and proximate nexus between the expenditure incurred and the income assessable under the head “Income from other sources”. The Hon’ble Supreme Court as well

DY COMMISSIONER OF INCOME TAX, MUMBAI vs. HITESH SHANTILAL MEHTA, MUMBAI

In the result, the cross-objections filed by the assessee are allowed

ITA 7798/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 144Section 147Section 268ASection 57

mandate that the expenditure must be incurred solely or exclusively for earning a particular item of income. What is required is a real and proximate nexus between the expenditure incurred and the income assessable under the head “Income from other sources”. Once such nexus is established, the allowability

DY COMMISSIONER OF INCOME TAX, MUMBAI vs. HITESH SHANTILAL MEHTA, MUMBAI

In the result, the cross-objections filed by the assessee are allowed

ITA 7797/MUM/2025[2004-05]Status: DisposedITAT Mumbai09 Feb 2026AY 2004-05

Bench: the Tribunal, as stipulated under CBDT Circular No.09/2024 dated 17.09.2024. It was also not the case of the Revenue that the present appeals fall within any of the exceptions carved out in the said Circular. In view of this admitted position and having regard to the binding nature of the Circular, which expressly applies even to pending appeals, the maintainability of the Revenue's appeals stands squarely governed by the said Circular. 3

Section 143(3)Section 144Section 147Section 268ASection 57

mandate that the expenditure must be incurred solely or exclusively for earning a particular item of income. What is required is a real and proximate nexus between the expenditure incurred and the income assessable under the head “Income from other sources”. Once such nexus is established, the allowability

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