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

ACIT, Circle-7(1), Delhi vs. First Global Services Private Limited, Delhi

Appeal is dismissed

ITA 9129/DEL/2025[2023-24]Status: DisposedITAT Delhi10 Jul 2026AY 2023-24

Bench: Ms. Madhumita Roy & Sh. Krinwant Sahay

For Appellant: NoneFor Respondent: Sh. Om Prakash, CIT DR
Section 145ASection 37(1)Section 43BSection 80J

Sunita, Near Bus Stand Khera Dabar Najafgarh, South West 1 vs. Income Tax Officer, Ward 4(1), Gurgaon

In the result, appeal of the assessee is allowed

ITA 6061/DEL/2026[2020-21]Status: DisposedITAT Delhi09 Jul 2026AY 2020-21

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21 Sunita, Vs. Income Tax Officer, Near Bus Stand Khera Dabar Ward 4(1), Najafgarh, South West 110073. Haryana-122001. Pan: Jitps5129G (Appellant) (Respondent) Assessee By Shri Dinesh Kumar, Adv. Department By Sh. Nirmal Nangia, Sr. Dr Date Of Hearing 09.07.2026 Date Of Pronouncement 09.07.2026

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

M/S Shikhar Enterprises, Bilaspur vs. ITO, Ward-1(1), Bilaspur

In the result, appeal of the assessee is allowed

ITA 440/RPR/2026[2019-20]Status: DisposedITAT Raipur06 Jul 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishra

For Appellant: Shri Sakshi Gopal Agrawal, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(1)Section 143(1)(a)Section 36

ACIT, Circle- 2(1)(1), Ghaziabad vs. Tarun Tulsian, Ghaziabad

The appeal of the assessee is allowed

ITA 7657/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Jun 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19

Section 143(3)Section 145ASection 68

Cauvery Iron and Steel India Limitedited, Hyderabad vs. Central Circle 7(3), Mumbai

ITA 4068/MUM/2025[2020-21]Status: DisposedITAT Mumbai03 Jun 2026AY 2020-21

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

Section 139(1)Section 143(1)Section 250Section 37Section 43B

Uma Organics, Vadodara vs. Income Tax Officer Ward 1(3)(1), Vadodara

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 366/AHD/2026[2023-24]Status: HeardITAT Ahmedabad29 May 2026AY 2023-24

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2023-24

For Appellant: Shri Sunil Talati, A.RFor Respondent: Shri VeerabadramVislavath, Sr. D.R
Section 139(9)Section 145Section 145ASection 154Section 250Section 44A

Income Tax Officer, Tuni vs. Sivaganesh Narise, S Annavaram

In the result, the appeal filed by the revenue is allowed for statistical purposes in terms of our aforesaid observations

ITA 711/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam13 May 2026AY 2021-22

Bench: Shri Ravish Sood & Shri Omkareshwar Chidaraआ.अपी.सं /Ita No.711/Viz/2025 (िनधा"रण वष"/Assessment Year:2021-22) Income Tax Officer, Vs. Sivaganesh Narise, Tuni. Tuni. Pan: Abdpn8712E (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid Hearing) राज" व "ारा/Revenue By: Shri K Prasad, Sr-Ar सुनवाई की तारीख/Date Of 04/05/2026 Hearing: घोषणा की तारीख/Date Of 13/05/2026 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 24/09/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 13/12/2022 For The Assessment Year (Ay) 2021-22. The 2 Ito Vs. Sivaganesh Narise

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri K Prasad, Sr-AR
Section 143(1)Section 143(2)Section 143(3)Section 145ASection 37Section 68

Income Tax Officer, Karnal vs. Prem Chand Madan, Karnal

In the result, both the appeals of the Revenue in ITA Nos

ITA 8559/DEL/2025[2016]Status: DisposedITAT Delhi13 May 2026

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rajeev Sachdeva, C.AFor Respondent: Shri Choudhary N.C. Roy, Sr. D.R

B & A Packaging India Limited, Balasore vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 663/CTK/2025[2022-23]Status: DisposedITAT Cuttack12 May 2026AY 2022-23

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am B & A Packaging India Limited Dcit, Circle 1(1) 21, Bolgopalpur Industrial Area, Aayakar Bhawan, Rajaswa Vihar, Vs. Balasore-756020, Odisha Bhubaneswar-751007, Odisha (Appellant) (Respondent) Pan No. Aabcb2140C Assessee By : Shri Partha Mukherjee, Ar Revenue By : Shri Vijay Singh, Dr Date Of Hearing: 12.05.2026 Date Of Pronouncement: 12.05.2026

For Appellant: Shri Partha Mukherjee, ARFor Respondent: Shri Vijay Singh, DR
Section 145A

Assisstant Commissioner of Income Tax, Mumbai vs. Dassault Systemes Solutions Lab Private Limited, Mumbai

In the result, the appeal of the revenue is partly allowed for statistical

ITA 6805/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 May 2026AY 2018-19

Bench: Shri Sandeep Gosian & Shri Bijayananda Prusethassisstant Commissioner Of Vs. Dassault Systemes Solutions Lab Income Tax Private Limited Ayakar Bhavan Churchgate, Plant 11, 3Rd Floor Pirojshanagar Mumbai-400079. Vikhroli West, Mumbai-400079. Pan/Gir No: Aaacz1421B (Appellant) (Respondent) Assessee By Shri Jeet Kamdar Revenue By Shri Annavaram Kosuri (Sr Ar) Date Of Hearing 11.05.2026 Date Of Pronouncement 13.07.2026 O R D E R Per Bijyananda Pruseth, Am:

Section 142(1)Section 145ASection 250

Welkin Developers, Mumbai vs. Asstt. Comm of Income Tax, CC 4(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5070/MUM/2025[2019-20]Status: DisposedITAT Mumbai16 Mar 2026AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Respondent: Shri Rajesh Upadhyay
Section 139(1)Section 143(3)Section 145ASection 250

Welkin Deveopers, Mumbai vs. Asstt.Comm. of Income Tax, CC 4(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5069/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Rajesh UpadhyayFor Respondent: Shri S. Anbuselvan (Sr. AR)
Section 139(1)Section 143(3)Section 145ASection 250

Dy. Commissioner of Income Tax, Cir - 2(1)(1), Surat vs. Shree Sayan Vibhag Sahakari Khand Udyog Mandli Ltd, Surat

In the result, both the appeals filed by the Revenue are dismissed

ITA 908/SRT/2025[2011-12]Status: DisposedITAT Surat27 Feb 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT(DR)For Respondent: Shri Akshay M Modi, AR
Section 143(3)Section 145ASection 155Section 37(1)Section 80P(2)(d)Section 80P(4)

Deputy Commissioner of Income Tax, Surat vs. Shree Sayan Vibhag Sahakari Khand Udyog Mandli Ltd, Surat

In the result, both the appeals filed by the Revenue are dismissed

ITA 901/SRT/2025[2014-15]Status: DisposedITAT Surat27 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Mukesh Jain, CIT(DR)For Respondent: Shri Akshay M Modi, AR
Section 143(3)Section 145ASection 155Section 37(1)Section 80P(2)(d)Section 80P(4)

Rajesh Sahu, Gurgaon vs. Assessing Officer, Nfau

In the result, appeal of the assessee is allowed

ITA 78/DEL/2026[2018-19]Status: DisposedITAT Delhi09 Feb 2026AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Rajesh Sahu, Vs. Assessing Officer, H. No. 2A, Sahu Lane, New Delhi Phase-2, Ashok Vihar, Gurgaon Pan: Avaps9917M (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

Deputy Commissioner of Income Tax 1(1)(2), Mumbai vs. Hindustan Unilever Limited, Mumbai

ITA 929/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80H

Hindustan Unilever Limited, Mumbai vs. Dy.CIT-1(1)(2), Mumbai

In the result, the appeal by the Revenue and cross-objection by the

ITA 1041/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05

Bench: Shri Om Prakash Kant

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80HSection 8O

Mahender Malik, Hisar vs. ITO, Ward -(1), Hisar

In the result, appeal of the assessee is allowed

ITA 5586/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Sh. Mahender Malik, Vs. Income Tax Officer, 388, Satroad Khurad, Near Ward-1, Adarsh High School, Hisar Hisar Pan: Bitpm5341N (Appellant) (Respondent) Assessee By Ms. Karishma Rathore, Adv. Sh. Mayank Patawari, Adv. Department By Sh. Yogeshwar Sharma, Sr. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 29.01.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1069269047(1), Dated 30.09.2024 Involving Proceedings Under Section 154 Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. For The Reasons Stated In The Assessee’S Condonation Averments, Delay Of 3 Days In Filing Of The Instant Appeal Is Condoned In Light Of Collector, Land & Acquisition Vs. Mst. Katiji & Others (1987) 167 Itr 471 (Sc). 3. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 4. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only.

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 154Section 263Section 28Section 56(2)(viii)

M/S Anjeneya Ispat Ltd., Saraikela vs. Deputy Commissione of Income Tax, Circele-1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 75/RAN/2022[2009-10]Status: DisposedITAT Ranchi06 Jan 2026AY 2009-10

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.75/Ran/2022 Assessment Year: 2009-10 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand- 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Cit(A)”) Dated 25.09.2017 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2019–20 Declaring A Total Income Of ₹62,64,116. The Case Was Selected For Complete Scrutiny. During The Relevant Previous Year, A Survey Operation Under Section 133A Of The Income-Tax Act, 1961 Was Conducted At The Business Premises Of The Assessee On 16.02.2019. Subsequently, Statutory Notices Under Sections 143(2) & 142(1) Of The Act Were Issued. In Response Thereto, The Assessee Appeared From Time To Time & Furnished Various Details & Documents As Called For. The Same Were Examined & Discussed By The Assessing Officer During The Course Of Assessment Proceedings. During

Section 10(23)Section 133ASection 133A(3)Section 145ASection 14ASection 250Section 40Section 69Section 69C

Raisoni Bagrecha Diamonds Private Limited, Jalgaon vs. Pne-C-(25)(1), Circle 1, Jalgaon

In the result, the appeals of the assessee in ITA No

ITA 2550/PUN/2025[2016-2017]Status: DisposedITAT Pune01 Jan 2026AY 2016-2017

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2548 & 2550/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 & 2016-17 Raisoni Bagrecha Diamonds Pne-C-(25)(1), Pvt. Ltd. 288, Baliram Peth, Circle-1, Jalgaon Jalgaon-425001, Maharashtra Vs. Pan : Aadcr 7439 N अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjay T. Tupe, Ca Department By : : Smt. Indira R. Adakil –Addl. Cit Date Of Hearing : 04-12-2025 Date Of Pronouncement : 01-01-2026 आदेश / Order Per Astha Chandra, Jm : The Appeals Filed By The Assessee Is Directed Against The Separate Order(S) Both Dated 14.08.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2015-16 & 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal :-

For Appellant: Shri Sanjay T. Tupe, CAFor Respondent: : Smt. Indira R. Adakil –Addl. CIT
Section 145ASection 69