Income Tax Case Laws

Background of the case In a significant ruling, the Mumbai Income Tax Appellate Tribunal (‘ITAT’), in the case of Fairbridge Capital (Mauritius) Limited, has delivered an important judgment clarifying the scope and applicability of Section 56(2)(x) of the Income-tax Act, 1961 (‘the Act’) in the context of conversion of Optionally Convertible Cumulative Redeemable Preference Shares […]

Background of the case In a recent ruling, the Supreme Court (“The Hon’ble Court”) in the case of M/s Jindal Equipment Consultancy Services Ltd (“the assessee” or “the Company”) adjudicated a batch of appeals concerning the taxability of shares received by shareholders upon amalgamation, specifically where the shares of the amalgamating company were alleged to […]

Background of the case In a recent ruling, the Supreme Court (‘SC’), in the case of Jupiter Capital Pvt Ltd (‘Company’ or ‘assessee’), examined the tax consequences of capital reduction and its treatment under the provisions of the Income Tax Act, 1961 (‘IT Act’), particularly Section 2(47) concerning the definition of ‘transfer’. The landmark judgement […]

Background of the case In a landmark judgment, the Supreme Court of India, in the case of Tiger Global International II Holdings & Ors. (2026 INSC 60), has settled several long-standing controversies relating to taxation of indirect transfers, treaty shopping, the evidentiary value of Tax Residency Certificates (“TRCs”), and the scope and application of General […]

In an interesting development in the case of Hinduja Global Solutions Limited (“HGSL”), the Bombay High Court, by its interim order dated 19 December 2025, admitted the writ petition filed by HGSL and granted interim relief. Background The GAAR panel had passed a directive characterizing the treatment of tax losses under the demerger of NXT […]