Section 145A of the Income Tax Act

Income-tax Act, 2025: s.277

Section 145A of the Income-tax Act, 1961 corresponds to section 277 (Method of accounting in certain cases) of the Income-tax Act, 2025.

Read section 277 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 145A is CIT v. State Bank of Bikaner & Jaipur (43 Taxmann.com 411), cited in 524 of the 656 judgments on BharatTax that turn on this section.

Leading authorities on Section 145A

CIT v. State Bank of Bikaner & Jaipur
43 Taxmann.com 411 · 2014 · High Court
524
citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

Rama Bai v. CIT
181 ITR 400 · 1990 · Supreme Court
258
citing judgments

Interest income is taxable on either an accrual or cash basis, determined by accounting principles. This method was applicable prior to legislative changes that simplified the taxation of interest income.

CIT v. Govindbhai Mamaiya
91 Taxmann.com 20 · 2018 · Supreme Court
205
citing judgments

Interest on enhanced compensation received under Section 28 of the Land Acquisition Act, 1894, is considered part of the compensation, not merely interest income, and is exigible to tax on a receipt basis.

V.M.Salgaocar & Bros.(P) Ltd. v. CIT
243 ITR 383 · 2000 · Supreme Court
189
citing judgments

An order by the Supreme Court dismissing a Special Leave Petition (SLP) at the threshold without detailed reasons does not constitute a declaration of law or a binding precedent. Such dismissal in limine offers no legal assistance.

Mahender Pal Narang v. CBDT
161 Taxmann.com 301 · 2024 · High Court
178
citing judgments

Interest received as enhanced compensation under Section 28 of the Land Acquisition Act, 1894, for compulsory acquisition of land is taxable as "income from other sources" under Sections 56(2)(viii) and 57(iv) of the Income-tax Act, 1961, and is not exempt under Section 10(37).

CIT v. Hindustan Coca Cola Beverages P Ltd.
331 ITR 192 · 2011 · High Court
152
citing judgments

The Principal Commissioner of Income Tax cannot exercise revisional jurisdiction under Section 263 if the Assessing Officer has taken one of two possible views on a debatable issue during assessment proceedings.

CIT v. Ganpat Ram Bisnoi
296 ITR 292 · 2008 · High Court
145
citing judgments

An assessment order cannot be revised under Section 263 for being erroneous due to a perceived lack of enquiry if the Assessing Officer has already conducted an enquiry, applied their mind, and accepted the assessee's explanation.

Movaliya Bhikhubhai Balabhai v. ITO TDS
388 ITR 343 · 2016 · High Court
128
citing judgments

Interest paid on compensation or enhanced compensation for compulsory acquisition of land forms part of the compensation itself and is not taxable as interest income under section 56(2)(viii) or section 145A.

Sham Lal Narula (Dr.) v. CIT
53 ITR 151 · 1964 · Supreme Court
100
citing judgments

Interest received under Section 28 of the Land Acquisition Act, 1894, on enhanced compensation does not form part of the compensation itself but is taxable as 'income from other sources', analogous to interest under Section 34 of the Act.

T.N.K. Govindaraju Chetty v. CIT
66 ITR 465 · 1967 · Supreme Court
89
citing judgments

Interest received under Sections 28 and 34 of the Land Acquisition Act, 1894, for delayed or enhanced compensation, is a revenue receipt and is taxable under the Income Tax Act.

Judgments on Section 145A

Sandeep, Sonipat vs. Income Tax Officer Ward-1, Sonipat

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

ITA 2392/DEL/2026[2014-15]Status: DisposedITAT Delhi18 Sept 2026AY 2014-15

Bench: Shri S.Rifaur Rahmansandeep, Vs. Ito, Ward 1, Village Badhkhalsa, Sonipat. Ps Rai, Sonipat – 131 001 (Haryana). (Pan : Ajmpr1910R) (Appellant) (Respondent) Assessee By : Shri Subodh Jain, Advocate Shri Samyak Jain, Ca Revenue By : Shri Manoj Kumar, Sr. Dr Date Of Hearing : 14.07.2026 Date Of Pronouncement : 18.09.2026 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre, Delhi [For Short ‘Ld. Cit (A)] Dated 08.01.2026 For The Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Has Not Filed Its Return Of Income. Based On The Above, Assessment Was Reopened. Based On The Information Available On Aims Module, The Assessee Has Received Cash Of 2 Rs.35,33,013/- On Account Of Interest Under Section 194A Of The Income- Tax Act, 1961 (For Short ‘The Act’). Accordingly Notice Under Section 148 Was Issued & Served On The Assessee. Subsequently, Assessee Filed Its Return Of Income As Required Under Section 148 Of The Act On 30.10.2021 Electronically Declaring Total Income Of Rs.1,03,687/-. Accordingly Notices Under Section 143(2) & 142(1) Were Issued & Served On The Assessee. During Assessment Proceedings, Ao Observed That Assessee Has Received Enhanced Interest Income From Land Acquisition Officer Of An Amount Of Rs.36,33,013/- On Which Tds Under Section 194A Was Deducted. He Observed That Assessee Has Claimed The Same As Exempt Income In Its Return Of Income. When The Details Were Called For, Assessee Has Submitted As Under:

For Appellant: Shri Subodh Jain, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 10(37)Section 143(2)Section 147Section 148Section 194ASection 250Section 28Section 34

Akhilesh Bansal, Gurgaon vs. ITO, Gurgaon

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

ITA 2394/DEL/2026[2018-19]Status: DisposedITAT Delhi27 Jul 2026AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singhakhilesh Bansal, Vs. Ito, Ward 1 (1), 47, Raj Niwas, Sector 5, Gurgaon. Gurgaon - 122 001 (Haryana). (Pan : Ahfpb1275J) (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi, Ca Shri Satyajeet Goyal, Ca Revenue By : Shri G.P. Singh, Sr. Dr Date Of Hearing : 01.07.2026 Date Of Pronouncement : 27.07.2026 O R D E R Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac) Dated 02.01.2026 For The Ay 2018-19. 2. Brief Facts Of The Case Are, In The Year Under Consideration, The Assessee Received Enhanced Compensation Amounting To Rs.2,15,77,773/- Together With Interest Of Rs.2,23,78,473/- Consequent To Compulsory Acquisition Of Land Situated In Village Badha, Tehsil Manesar, District Gurugram By 2 Huda. The Land Was Originally Purchased In The Year 2007. The Assessee Claimed The Enhanced Compensation & Damages In The Form Of Interest U/S 28 Of The Land Acquisition Act As Exempt On The Ground That The Land Acquired Was Rural Agricultural Land Situated Beyond The Prescribed Municipal Limits And, Therefore, Did Not Constitute A "Capital Asset" Within The Meaning Of Section 2(14)(Iii) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Assessing Officer, However, Rejected The Claim & Treated The Enhanced Compensation As Taxable Under Section 45(5) & The Interest As Taxable Under The Head "Income From Other Sources".

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Shri G.P. Singh, Sr. DR
Section 2(14)Section 2(14)(iii)Section 28Section 45(5)