Section 10(10C) of the Income Tax Act

Income-tax Act, 2025: s.19

Section 10(10C) of the Income-tax Act, 1961 corresponds to section 19 (Deductions from salaries) of the Income-tax Act, 2025.

Read section 19 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 10(10C) is CIT v. Bank of Tokyo Ltd. (71 Taxmann 85), cited in 30 of the 899 judgments on BharatTax that turn on this section.

Leading authorities on Section 10(10C)

CIT v. Bank of Tokyo Ltd.
71 Taxmann 85 · 1993 · High Court
30
citing judgments

The refund of guarantee commission for the unexpired period of a guarantee contract, where the contract is revoked prematurely, is a valid deduction for the assessee-bank.

CIT v. Bharat Carbon & Ribbon Mfg. Co. (P) Ltd.
239 ITR 505 · 1999 · Supreme Court
25
citing judgments

Statutory liabilities, like customs duty, are deductible only in the year they are actually paid, regardless of the assessee's accounting method, as per Section 43B.

SSPDL Ltd vs. DCIT, 33 TAXMANN.COM 447. 4) CIT v. Suzlon Energy Ltd., 33
32 Taxmann.com 276 · 2013 · High Court
15
citing judgments

The Assessing Officer cannot make additions under Section 14A concerning investments in shares if the investment was not made for future benefit and was intended for business purposes.

En-vision Enviro Engineers (P.) Ltd. v. DCIT, Circle-1, Surat
150 TTJ 621 · 2012 · ITAT
12
citing judgments

Engaging in the treatment of bio-medical waste qualifies as maintaining or developing an eligible infrastructural facility under Section 80IA(4) for availing deductions.

R 217 (Delhi) (HC) 2. National Agricultural Co-operative Marketing Federation of India Ltd. v. CIT
393 ITR 666 · 2017 · High Court
12
citing judgments

A liability incurred by an assessee, even if disputed, is deductible in the year it is incurred and becomes enforceable, such as through an arbitration award or court decree, regardless of subsequent legal challenges or stays.

105 Taxman 256 (Del.) 6. DCIT v. Warner Lambert (I) Pvt. Ltd.
143 TTJ 571 · 2012 · ITAT
8
citing judgments
Synergy Waste Management (P) Ltd. v. The ACIl: Hisar
88 Taxmann.com 405 · 2017 · High Court
8
citing judgments
CIT v. Ajit Kumar Bose
165 ITR 90 · 1987 · High Court
7
citing judgments
Gujarat Steel Tubes Ltd. v. CIT
210 ITR 358 · 1994 · Reported
5
citing judgments
Surat District Coop. Bank Ltd. v. ACIT
152 Taxmann.com 549 · Reported
4
citing judgments

Judgments on Section 10(10C)

Ram Dattatray Kaldate, Aurangabad vs. Income Tax Officer Ward 1(1), Aurangabad

In the result, the appeal of the assessee is allowed

ITA 2177/PUN/2025[2019-20]Status: DisposedITAT Pune09 Jun 2026AY 2019-20

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2177/Pun/2025 धििाारण वर्ा / Assessment Year : 2019-20 Ram Dattatray Kaldate, Ito, Ward-1(1), Vijay Kasnale, Plot No. Rm 103, Aurangabad Bajajnagar Midc Waluj, Vs. Aurangabad-431136 Pan : Asupk0994M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Nikhil S Pathak & Archana Shetty Department By : Shri Sandip Pawar Date Of Hearing : 08-04-2026 Date Of 09-06-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 24.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2019-20. 2. Briefly Stated Facts Of The Case Are That The Assessee Is An Individual & Ex-Employee Of M/S. Pfizer Healthcare India Pvt. Ltd., Aurangabad (“Pfizer India”). For Ay 2019-20, The Assessee Filed His Return Of Income On 29.07.2019 Declaring Income Of Rs.60,34,360/- & Claiming Relief Of Rs.18,28,958/- U/S 89 Of The Income Tax Act, 1961 (The “Act”). The Case Of The Assessee Was Selected For Scrutiny Under Cass For Issues Relating To Refund Claim & Relief For Arrear Salary Or Advance Salary. During The Ay 2019-20, The Assessee Received Rs.54,64,480/- As A Full & Final Settlement On Account Of His Voluntary Retirement From His Employment With Pfizer India Pursuant To Pfizer Healthcare India Private Limited Finance Scheme For Employees At Aurangabad, 2019 (“Scheme”) Which Was Framed By The Company & Offered To The Assessee Due To Closure Of Its Plant At Aurangabad. The Assessee Claimed The Said Amount As 2

For Appellant: Shri Nikhil S Pathak &For Respondent: Shri Sandip Pawar
Section 143(3)Section 56(2)(xi)Section 89

Prakash Sukhdeo Sonawane, Aurangabad vs. Income Tax Officer, Ward 1(1), Aurangabad

In the result, the appeal of the assessee is allowed

ITA 2180/PUN/2025[2019-20]Status: DisposedITAT Pune08 Jun 2026AY 2019-20

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2180/Pun/2025 धििाारण वर्ा / Assessment Year : 2019-20 Prakash Sukhdeo Sonawane, Ito, Ward-1(1), Rm 95 Bl No. 06, Bajajnagar, Aurangabad Midc Waluj, Aurangabad-431136 Vs. Pan : Bpqps2224J अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Nikhil S Pathak & Archana Shetty Department By : Shri Sandip Pawar Date Of Hearing : 08-04-2026 Date Of 08-06-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 24.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2019-20. 2. Briefly Stated Facts Of The Case Are That The Assessee Is An Individual & Ex-Employee Of M/S. Pfizer Healthcare India Pvt. Ltd., Aurangabad (“Pfizer India”). For Ay 2019-20, The Assessee Filed His Return Of Income Claiming A Refund Of Rs.22,97,400/- & Relief Of Rs.21,77,119/- U/S 89 Of The Income Tax Act, 1961 (The “Act”) For Advance Salary Received. During The Ay 2019-20, The Assessee Opted To Retire Voluntarily From His Employment With Pfizer India Pursuant To The Pfizer Healthcare India Private Limited Finance Scheme For Employees At Aurangabad, 2019 (“Scheme”) Which Was Framed By The Company Due To Closure Of Its Plant At Aurangabad. Under The Said Scheme, The Assessee Received An Amount Aggregating To Rs.65,21,105/-, However, The Said Amount Was Not Claimed To Be A Capital Receipt In His Return Of Income For Ay 2019-20 But The 2

For Appellant: Shri Nikhil S Pathak &For Respondent: Shri Sandip Pawar
Section 142(1)Section 143(3)Section 56(2)(xi)Section 89