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

Income Tax Officer, Ward-1, Ichalkaranji vs. Navdurga Yarns LLP, Ichalkaranji

In the result, the appeal of the Revenue is allowed for statistical

ITA 1287/PUN/2024[2022-23]Status: DisposedITAT Pune31 Jan 2025AY 2022-23

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1287/Pun/2024 निर्धारण वर्ष / Assessment Year : 2022-23 Income Tax Officer, Ward - 1, Ichalkaranji अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Navdurga Yarns Llp, 12/537/1, Near Hotel Man, Vs. Shahu Corner, Ichalkaranji-416115 Pan : Aapfn7837F प्रत्यर्थी / Respondent Shri Bhuvnesh V. Kankani Shri Amol Khairnar 07-11-2024 31-01-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Revenue Is Directed Against The Order Dated 05.04.2024 Of The Ld. Additional/Joint Commissioner Of Income Tax (Appeals)-2, Vadodara [“Addl./Jcit(A)"] Pertaining To Assessment Year ("Ay") 2022-23. 2. Briefly Stated, The Facts Of The Case Are That The Assessee Is A Firm. It Filed Its Original Return Of Income For Ay 2022-23 On 22.10.2022 Declaring Total Income At Rs.2,74,64,880/-. The Return Was Processed U/S 143(1) Of The Income Tax Act, 1961 (The “Act"). An Intimation Order Dated 07.06.2023 Was Passed By The Ld. Assessing Officer, Cpc Bengaluru (“Ao”) Assessing Total Income At Rs.13,01,40,970/- & Raising A Demand Of Rs.4,16,78,170/-. The Ld. Ao Made An Addition Of Rs.10,26,76,090/- Under The Head, “Increase In Profit Or Decrease In Loss On Account Of Icds Adjustments & Deviation In Method Of Valuation Of Stock (Column 3A + 4D Of Part A-Oi)”. 3. Aggrieved By The Order Of The Ld. Ao Passed U/S 143(1) Of The Act, The Assessee Appealed Before The Ld. Addl./Jcit(A). Before The Ld. Addl./Jcit(A), The Assessee Submitted That The Books Of Account Of The Assessee Were Audited As Required Under The Relevant Provisions Of The Act & The Audit Report Was Submitted Electronically By The Assessee. The 2

For Appellant: Department byFor Respondent: Date of hearing
Section 143(1)Section 145A