Direct Tax Updates for April 2025

NOTIFICATION G.S.R. 252(E) [NO. 35/2025/F.NO. 370142/11/2025-TPL], DATED 22-4-2025

The CBDT vide notification dated 22.04.2025; notifies 10 luxury goods liable to TCS; list includes home theatre systems, shoes, handbags etc. 

NOTIFICATION NO. 25/2025 [G.S.R. 217(E)/F. NO. 370142/1/2025-TPL], DATED 3-4-2025

Person allotted PAN based on enrollment ID shall intimate his Aadhaar Number on or before 31-12-2025.

NOTIFICATION NO. 30/2025 [G.S.R. 221(E)/F.NO. 370142/29/2024-TPL], DATED 7-4-2025

The CBDT vide notification dated 07.04.2025; notifies form ‘ITR-B’ for furnishing ITR for block assessment.

NOTIFICATION S.O. 1644(E) [NO. 31/2025/F.NO. 225/06/2024/ITA-II], DATED 7-4-2025

The CBDT notifies bonds issued by HUDCO as ‘long-term specified asset’ for Sec. 54EC exemption.

NOTIFICATION S.O. 1774(E) [NO. 34/2025/F.NO. 300164/2/2024-ITA-I], DATED 17-4-2025

Govt. notifies ‘Ten Year Zero Coupon Bond of Housing and Urban Development Corporation Ltd.’ as zero coupon bond

Important Judicial Precedents

SLP dismissed against HC’s ruling that AO is required to supply info. to assessee before issuing notice u/s 148A

[2025] 173 taxmann.com 687 (SC) Chaturbhuj Gattani vs. Income-tax Officer

SLP dismissed against order of High Court that section 148A mandates Assessing Officer only to supply information before issuing notice under section 148A in prescribed manner and not other material on basis of which it has formed prima facie opinion that income of assessee chargeable to tax has escaped assessment

Jewellery seized during search to be released if no additions were made in assessee’s hands: HC

[2025] 173 taxmann.com 519 (Gujarat-HC) Nayanaben Hasmukhbhai Patel vs. PCIT

Where assessee had already paid tax on addition made for seized jewellery, in absence of any outstanding liability to be discharged for relevant assessment year, jewellery could not be retained for recovery of outstanding demand for any subsequent assessment years

Reassessment based on third party info. that assessee was beneficiary of bogus LTCG without implicating him rightly quashed

[2025] 173 taxmann.com 834 (Delhi-HC) Abha Gupta vs. Income-tax Office

Section 148, read with section 147, of the Income-tax Act, 1961 – Income Escaping Assessment – Issue of notice for (Reassessment) – Assessment year 2013-14 – Assessing Officer issued notice under section 148 on basis of information received from Investigation Wing relating to certain share transactions involving one Dayand Singh, alleging that sell trades exceeded buy trades and assessee was beneficiary of bogus LTCG – Objections raised by assessee to initiation of reassessment proceedings were rejected – Whether, since reasons recorded for reopening were based solely on transactions of third party and failed to allude to any material implicating petitioner in alleged manipulation of penny scrips, reassessment notice under section 148 and order disposing objections were to be quashed – Held, yes [Paras 14 and 15] [In favour of assessee]

Donation given by trust to other registered trusts to be considered as application of income: ITAT

[2025] 173 taxmann.com 99 (Chandigarh – Trib.) DCIT vs. Indo Global Education Foundation

Where assessee charitable trust, engaged in providing education, had given donations to other educational trusts, which were also registered under section 12AA, and claimed that by way of such donations object of providing education was fulfilled, said donations were to be considered as application of income and were to be allowed as exemption under section 11.

SLP dismissed against ruling that sec. 263 revision isn’t justified if there was no dispute with regard to sale & purchase

[2025] 173 taxmann.com 880 (SC) PCIT vs. Green Touch Vincom (P.) Ltd

SLP dismissed against order of High Court that where Assessing Officer found that assessee had shown very low net profit against large gross receipts in its profit and loss account by inflating purchases and other expenses and Assessing Officer completed assessment by fixing disallowance of alleged expenses at 5 per cent, since there was no dispute with regard to assessee’s sale and purchase figures, assumption of jurisdiction by Commissioner under section 263 was not justified.

Provisions of Sec. 40A(7) would override Sec. 43B in case of an approved gratuity fund: Madras HC

[2025] 173 taxmann.com 884 (Madras-HC) Sanmar Speciality Chemicals Ltd. vs. Assistant Commissioner of Income-tax

Where assessee-company made provision towards approved gratuity fund with LIC, since provisions of section 40A(7)(b) were specific to a claim of deduction based on provision for payment towards an approved gratuity fund, same would take precedence over general provision of section 43B and claim of deduction towards said gratuity fund was to be allowed.

Prior period exp. to be considered while computing book profit u/s 115JA if disclosed in P&L A/c: HC

[2025] 173 taxmann.com 918 (Madras -HC) Ramakrishna Mills (CBE) Ltd. vs. JCIT

Where prior period expenses had crystallised and were incurred in relevant financial year, such expenses were to be allowed in computation of book profit under section 115JA, and revision under section 263 disallowing such claim was unsustainable.

AO to pass fresh order disposing of objections to reassessment notice if not dealt with earlier: HC

[2025] 174 taxmann.com 64 (Bombay-HC) Modern Realty (P.) Ltd. vs. DCIT

Section 148, read with section 147, of the Income-tax Act, 1961 – Income escaping assessment – Issue of notice for (Objections) – Assessment year 2015-16 – Assessing Officer issued a reopening notice upon assessee – Assessee raised objections against reopening of assessment – Assessing Officer passed an order disposing of objections raised by assessee – However, it was found that Assessing Officer had not dealt with objections raised by assessee – Whether assessee having filed only one set of objections, and without dealing with those objections, to say that objections followed by cross objections are an endless process, which should end at a certain point in time, was not justified – Held, yes – Whether since Assessing Officer had not dealt with objections raised by assessee, matter was to be remanded back to Assessing Officer to pass a fresh order disposing of objections raised by assessee – Held, yes [Paras 8 to10] [Matter remanded]

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