NATIONAL LAW UNIVERSITY ODISHA

Programme: BALLB(Hons.) & BBALLB(Hons.)

Semester: VIII (Even Semester)
Course Name: Direct Taxation
(Compulsory Paper – 4 Credits)

Course Prepared by: Dr. Priyanka Anand

Associate Professor of Law, NLUO

Course Co-ordinators:
Dr. Priyanka Anand, Associate Professor of Law, NLUO
Dr. Kaushiki Brahma, Assistant Professor of Law, NLUO
Dr. Mayank Mishra, Assistant Professor of Law, NLUO
 COURSE DESCRIPTION

Brief Description of the Course:

This course on Direct Taxation is designed to provide law students with a comprehensive
understanding of the legal frameworks governing direct taxes. In an ever-evolving global landscape,
the study of direct taxation becomes crucial for aspiring legal professionals. This course delves into
the intricacies of direct tax laws, exploring both national and international perspectives to equip
students with the knowledge and skills necessary for a successful career in taxation law.

Rationale behind the Course:

The rationale behind offering a course on Direct Taxation lies in the fundamental role that taxation
plays in a nation's economic and legal structure. Understanding direct taxation is imperative for law
students as it forms the basis for legal practice in the field of taxation law. This course aims to bridge
the gap between theoretical knowledge and practical application, providing students with a nuanced
understanding of direct tax laws, regulations, and their implications.

 Emerging National and Global Requirements:

The course is tailored to meet emerging national and global requirements, aligning with
contemporary issues such as sustainability, gender sensitivity, environmental concerns, human values,
professional ethics, and the development of creative and divergent competencies.

 Sustainability:

Understanding the tax implications on sustainable practices and green initiatives is integral to the
course. Students will explore how tax laws can incentivize environmentally responsible behavior and
contribute to sustainable development.

 Gender Sensitivity:

The course incorporates a gender-sensitive approach to direct taxation, acknowledging the

differential impact of tax policies on different genders. Students will critically examine how tax laws
can be crafted to promote gender equality and address gender-based economic disparities.

 Environment:
The course addresses the environmental impact of tax policies, considering how taxation can be
leveraged to encourage environmentally friendly practices and discourage harmful ones. Students
will explore the intersection of tax law and environmental sustainability.

 Human Values:

Direct taxation is contextualized within the framework of human values, emphasizing the ethical
considerations involved in tax practice. Students will engage with case studies and scenarios that
prompt ethical reflection, fostering a values-driven approach to tax law.

 Professional Ethics:

The course places a strong emphasis on professional ethics within the context of direct taxation.
Students will explore ethical considerations, integrity, and professionalism in the practice of tax law,
preparing them for the ethical challenges they may encounter in their careers.

 Development of Creative and Divergent Competency:

Recognizing the dynamic nature of taxation, the course encourages the development of creative and
divergent competencies. Students will be challenged to think innovatively, analyze complex tax
scenarios, and propose creative solutions to address evolving fiscal challenges.

In conclusion, this course on Direct Taxation for law students goes beyond the traditional
boundaries of tax law education. By incorporating emerging national and global requirements related
to sustainability, gender sensitivity, environment, human values, professional ethics, and creative
competencies, it aims to produce well-rounded legal professionals equipped to navigate the
complexities of the contemporary tax landscape.

The course emphasises the cultivation of innovative and varied skills in response to the ever-
changing nature of taxation. Students will be presented with opportunities to engage in imaginative
thinking, critically analyse intricate tax issues, and develop inventive proposals to effectively tackle
the ever-changing fiscal challenges.

In summary, the Direct Taxation course designed for law students extends beyond the conventional
scope of tax law instruction. The objective of this initiative is to cultivate a comprehensive skill set
among legal professionals, enabling them to effectively navigate the intricate and multifaceted
contemporary tax environment. This is achieved by integrating emerging national and global
standards pertaining to sustainability, gender sensitivity, environmental concerns, human values,
professional ethics, and creative competencies.

Course Objectives Based on Bloom's Taxonomy:

1. Knowledge:

 Develop a comprehensive understanding of the fundamental principles and concepts of

direct taxation, including income tax, corporate tax, and international taxation.
 Acquire knowledge of the relevant legal frameworks, statutes, and case laws governing direct
taxation in both national and international contexts.
 Demonstrate proficiency in interpreting and applying complex tax regulations.

2. Skill:

 Develop analytical skills to assess and evaluate the tax implications of various financial
transactions and business structures.
 Enhance research skills to effectively navigate tax laws, rulings, and precedents for legal
problem-solving.
 Gain practical skills in preparing tax documents, including tax returns and legal opinions,
adhering to professional standards.

3. Ethics:

 Cultivate a strong ethical foundation by critically examining the ethical considerations

inherent in tax practice.
 Develop an ethical decision-making framework for addressing dilemmas and challenges
encountered in the field of direct taxation.
 Demonstrate an understanding of professional responsibility, integrity, and ethical behavior
in the context of tax law.

4. Attitude:

 Foster a positive attitude towards continuous learning and adaptation to evolving tax laws
and regulations.
  Cultivate a sense of responsibility and accountability in applying tax laws ethically and
professionally.
 Develop an attitude of social responsibility by considering the broader impact of tax policies
on various stakeholders.

Course Outcomes:

1. Employability:

 Equip students with the knowledge and skills demanded by the legal profession in the field
of direct taxation.
 Enhance employability by providing practical insights into real-world tax scenarios, making
students job-ready.

2. Skill Development:

 Develop practical skills in tax planning, compliance, and dispute resolution, enhancing
students' ability to navigate complex tax issues.
 Cultivate research and problem-solving skills essential for addressing intricate tax challenges.

3. Academic Orientation:

 Foster a strong academic orientation by encouraging critical thinking, legal analysis, and
research methodologies specific to direct taxation.
 Prepare students for advanced studies in tax law or related fields.

4. Entrepreneurship:

 Instill an entrepreneurial mindset by integrating tax planning and strategy into business
ventures.
 Enable students to understand the tax implications of entrepreneurial activities and make
informed decisions for business sustainability.

5. Problem-Solving Attitude:

 Develop a problem-solving attitude by presenting students with real-world tax scenarios and
guiding them through the analysis and resolution of complex issues.
  Encourage creativity in finding innovative solutions to tax-related challenges.

6. Advocacy Capacity:

 Enhance students' advocacy capacity by honing their ability to communicate and argue tax
positions persuasively.
 Develop skills in presenting legal arguments and justifications in the context of tax disputes
and litigation.

In conclusion, the course aims to provide a holistic educational experience, aligning with Bloom's
Taxonomy to nurture knowledge, skills, ethics, and attitudes conducive to success in the field of
direct taxation. The outcomes extend beyond academic achievements, fostering employability, skill
development, academic orientation, entrepreneurship, problem-solving attitudes, and advocacy
capacity.

Teaching Learning Methodology:

 Lecture method
 Case analysis and discussion
 Class room presentation

EVALUATION SCHEME

SERIAL EXAM NAME MARKS

NUMBER

1. Internal Assessment

a. Research Paper 20

b. Viva on Research Paper 10

2. End Term Examination 70

Total 100
 COURSE SYLLABUS

Module I : Introduction
 Overview of taxation system in India - Direct and Indirect Taxes
 Applicability of the Income Tax Act, 1961
 Basic concepts : India, Person, Inccome, Assessee, Assessment year, Previous year,
Finance Act
 Charge of Income Tax - (Sec. 4)
Cases:
1. Raghuvanshi Mills Ltd. V. CIT, (1952) 22 ITR 484 (SC)
2. Bangalore Club Ltd. V. CIT ,(2013) 29 taxmann.com 29/212 Taxman 566/350 ITR 509
(SC)
3. CIT v. SitaldasTirathdas, (1961) 41 ITR 367 (SC)
4. CIT v. Sunil j. Kinariwala, (2003) 179 CTR. (SC) 15
5. Maharaja Chintamani Saran Nath Sah Deo v. CIT, [1982] 133 ITR 658.
6. Provincial Superior v UOI [2021] 438 ITR 548 (Kerala)
7. Tata Teleservices Ltd. V CBDT [2016] 240 Taxman 182 (Delhi)
8. Sanjeev Lal v CIT [2014] 225 Taxman 239 (SC)
9. Brahm Datt v. Asst. CIT [2019] 260 Taxman 380

Module II : Scope of Total Income and Residential Status

 Total Income
 Scope of Total Income - Incidence of Tax - (Sec. 5)
 Test of residence for taxable entities - (Sec. 6)
 Income received or deemed to be received - (Sec. 7)
 Income deemed to accrue or arise in India - (Sec. 9 )
 Heads of income tax - (Sec. 14)
Cases:
 1. V.V.R.N.M. Subayyachettiar v. C.I.T., [1951] 019 ITR 0168 (SC).
2. Narottam and Parekh ltd. v. C.I.T., (1953) 55 BOMLR 790
3. CIT v. Suresh Nanda [2015] 375 ITR 172 (Del)
4. CIT v. Nandlal Gandlal[1960]40 ITR 1 (SC)
5. Performing Right Society Ltd. V. CIT [1977] 106 ITR 11 (SC)
6. Volkswagen Finance (P.) Ltd. V. ITO (2020) 79 ITR (T) 447 (Mumbai Tribunal)
7. Barendra Pd. Ray v. ITO (1981) 6 Taxman 19 (SC)
8. Pfizer Corporation v. CIT [2003] 129 Taxman 459 (Bom)

Module III : Income under the head 'Salaries'

 Computation of Income under the head 'Salaries'
 Basis of Charge - (Sec. 15)
 Meaning of Salary
 Treatment of Entertainment Allowance
 Tax on Employment (Professional Tax)
 Tax on Perquisites - (Sec. 10(10CC))
 Treatment of House Rent Allowance - (Sec. 10 (13A))
 Treatment of Retirement Benefits
 Treatment of Gratuity - (Sec. 10(10))
 Treatment of Commuted Pension - (Sec. 10(10A))
 Treatment of Leave Salary - (Sec. 10(10AA))
 Retrenchment Compensation - (sec. 10(10B))
 Compensation received on Voluntary Retirement - (Sec. 10(10C))
 Treatment of Provident Fund
 Perquisites - (Sec. 17(2))
 Taxability of Perquisites - Taxable in hands of all employees and taxable only in
case of specified employees
 Valuation of Perquisites -:
 Rent Free accommodation or accommodation provided at concessional rate
  Valuation of obligation of Employee discharged by the employer
 Valuation of benefits provided to the Employee discharged by the employer
 Value of Life Insurance Premium paid/payable by the employer
 Value of any specified security or sweat equity hare
 Contribution to an approved superannuation fund
 Fringe benefits or amenities which shall be taxable perquisites in the hands of all
employees
 Medical Facility
 Profits in lieu of salary (Sec. 17(3))
Cases:
1. Ram Prasad v. C.I.T., (1972)86 ITR 122 (SC)
2. CIT v. B.P. Dalmia [1993] 71 Taxman 52
3. C.I.T. v. L.W. Russel, AIR 1965 SC 49
4. Hosmat Hospital P. Ltd. V. Asst. CIT (2016) 73 taxman.com 147
5. ITC Hotels v. CIT (2016) 68 taxmann.com 323
6. UOI v. Society of Mary Immaculate (Tamil Nadu), Madras (2019) 103 taxmann.com 336
7. Mrs. Sugra Sulaiman v. CIT (1990) 44 Taxman 1
8. Bajrang Pd. Ramdharani v. ACIT (2013) 37 taxmann.com 186

Module IV : Income from House Property

 Chargeability – Sec. 22
 Annual Value of a Property – Sec 23
 Cases of Composite Rent
 Treatment of Unrealised rent – Explanation to sec 23(1)
 Deductions from Income from House Property – Sec 24
 Subsequent recovery of Unrealised rent - Sec 25AA
 Special provisions for Arrears of rent received – Sec. 25B
 Property owned by co-owners - Sec 26
 Deemed Owners – Sec 27
Cases:
1. CIT v. Kaniyalal Nimani (1979) 120 ITR 892 (Cal.)
2. M. Ramalakshmi Reddi v. CIT [1998] 100 Taxman 509
3. CIT v. Parbutty Churn Law [1965] 57 ITR 609 (Cal.)
4. D.R. Sunder raj v. CIT (1979) 2 Taxman 458
5. Smt. Jashvidaben C. Mehta v. CIT [1988] 37 Taxman 249
6. East India housing and land development trust ltd, v. Commissioner of income-tax, west.
Bengal, (1961) 42 ITR 49
7. R.b. Jodhamalkuthiala v. C.I.T., (1971) 82 ITR 570 (SC)
8. CIT v. Veerabhadra Industries [1999] 106 Taxman 370

Module V: Income under the head 'Income from Business or Profession'

 Capital Expenditure and Revenue Expenditure
 Capital Receipt and Revenue Receipt
 Business or Profession
 Chargeability / Scope of Income under the head Profit and gains from Business or
Profession – Sec. 28
 Rent, Rates, taxes, Repairs and insurance of Buildings - (Sec. 30)
 Repairs and insurance of Machinery, Plant and Furniture - (Sec. 31)
 Site Restoration Fund - Sec. 33 ABA
 Expenses on Amalgamation - (Sec. 35 DD)
 Expenses on VRS Compensation - (Sec. 35 DDA)
 Depreciation - (Sec. 32)
 Difference between depreciation under Accounting and Income Tax Act
 Conditions for allowance
 Block of Assets
 Rates of Depreciation
 Computation of WDV and depreciation
 Actual Cost - (Sec. 43(1) & Notional Actual Cost)
  Additional Depreciation
 Depreciation in Power Sector Units
 Unabsorbed Depreciation - (Sec. 32(2))
 Proportionate Depreciation
 Expenses on Scientific Research - (Sec. 35)
Cases:
1. Manohar Singh v CIT (1965) 58 ITR 592 (Pun & Har)
2. Raja J. Rameshwar Rao v. CIT (1961) 42 ITR 179 (SC)
3. CIT v. Moti Chand Khajanchi(1987) 34 Taxman 498
4. Ms. Priyanka Chopra v. Dy. CIT (2018) 89 Taxman.com 286
5. ACIT v. Sharukh Khan (2017) 84 Taxman.com 209
6. Shiv Raj Gupta V. CIT [2020] 117 taxmann.com 871
7. CIT v. Pangal Vittal Nayak & Co. (P) Ltd. (1969)74 ITR 754 (SC)
8. Whittle Anderson Ltd. v. CIT, (1971) 79 ITR 613 (Bom.)

Module VI : Income under the head 'Capital Gains'

 Basis of Charge – Sec 45
 Definitions :
o Capital Asset [Sec 2 (14)];
o Transfer [Sec. 2(47)];
o Short Term Capital Assets [Sec. 2(42A)]; Short term Capital Gains
o Long Term Capital Assets [Sec. 2(29A)]; Long Term Capital Gains

 What are not Transfer (Sec 47)

 Computation of Capital Gain – Sec. 48
Cases:
1. CIT v. H.H. Maharani Usha Devi [1998] 98 Taxman 309
2. CIT v. Gemini Pictures Circuit (P.) ltd. [1996] 85 Taxman 594
3. CIT v. Ramaswamy Mudaliar (1993) 66 Taxman 469
4. RasiklalChmanlal Nagri v. CWT(1965) 56 ITR 608 (Guj.)
 5. CIT v. RasiklalManeklal (HUF) (1989)43 Taxman 259
6. CIT v. G. Narasimhan (1999) 102 Taxman 66 (SC)
7. Pr. CIT v. Chuni Lal Bhagat [2019] 103 Taxmann.com 379 (SC)
8. N. Bagavathy Ammal v. C.I.T. Jt., (2003) 23 SITC 317 (SC)
9. C.I.T. v. Rajendra Prasad Moody, [1978] 115 ITR 519

Module VII : Income under the head 'Income from other Sources'
 Treatment of Winnings from Lotteries, crossword puzzles, Horse races and card
games, etc.
 Tax treatment of dividends, interest on securities
 Computing income from machinery, plant or furniture let on hire
 Computation of income from composite letting of building, machinery, plant or
furniture
 Permissible Deductions
Cases:
1. Commissioner of Income tax v. G. R. Karthikeyan, 1993 SCR (3) 328
2. Express Newspapers (P.) Ltd. v. CIT [1997] 92 taxman 496
3. Jay Metal Industries (P.) Ltd. v. CIT (2017) 84 Taxman.com 11
4. M.K. Dar v. CIT (1982) 8 Taxman 176
5. CIT v. Bokaro Steel Ltd. (1999) 102 Taxman 94

Module VIII: Agricultural Income

 Agricultural Income – sec 2(1A)
 Exemptions of agricultural Income - Sec 10(1)
Cases:
1. Bacha f. Guzdar v. Comm. of Income Tax, 1955 SCR (1) 876
2. Premier construction co. Ltd. v. C.I.T., Bombay City; (1948) 16. ITR 380
3. C.I.T.. v. Raja Benoy Kumar Sahas Roy, [1957) 32 ITR 466,
4. C.I.T. v. Maddi Venkatasubbaya, (1983) 144 ITR 373 (AP)
 5. C.I.T. Poona v. H. G. Date, (1971) 082 ITR 0071 (Bom)
6. K. Lakshmanan & co. v. C.I.T., (1999) 239 ITR 597(SC)

Module IX: Contextualising Tax Administration and Adjudication

 Overview of Tax Administration and Adjudication
 Income Tax Authorities
 Settlement Commission
 Appeals-
 Revision by Central Government
 Gender & Tax laws
 Tax and Environment
 Ethical Considerations in Tax Practice
Reference Readings:
 Association of Old Settlers of Sikkim v. Union of India, 2023 SCC OnLine SC 38
 Gender equality and taxation in India: An unequal burden?, , TAX. GEND. EQUITY 122–146
(2010), https://www.taylorfrancis.com/chapters/edit/10.4324/9780203852958-12/gender-
equality-taxation-india-unequal-burden-pinaki-chakraborty-lekha-chakraborty
 Edward J. McCaffery, Slouching Towards Equality: Gender Discrimination, Market
Efficiency, and Social Change (1993), https://papers.ssrn.com/abstract=3684003 (last
visited Jul 16, 2023).

Module X : Concepts of Tax Planning and Management

 Tax Planning
 Tax Evasion
 Tax Avoidance
 Transfer Pricing rules in India – An overview
Cases:
1. Azaadi BachaoAndolan v UOI,(2003) 263 ITR 706 (SC)
2. McDowell & Co. Ltd. v. CTO, (1985) 3 SCC 230
3. Vodafone International Holdings B.V. V. Union Of India &Anr.; [2012] 1 S.C.R. 573
REFERENCE READINGS

 Singhania, Dr. V. & Singhania, Dr. K. ; Direct Taxes, Law and Practice, 43nd edition,
Taxmann Publication Pvt. Ltd., New Delhi (2014-15). ™

 Ahuja, Dr. Girish & Gupta, Dr. Ravi; Professional Approach to Direct Taxes, Law and
Practice, 21th edition, Bharat Publication Law House Pvt. Ltd., New Delhi, (2011-12). ™

 Vayas, Dinesh (ed.); Kanga, Palkhivala and Vyas; The Law and Practic of INCOME
TAX, 9th edn.,Vol.I& II, Butterworths, New Delhi (2004). ™

 Singhania, Dr. V. & Singhania, Dr. K. ; Students’ Guide To Income Tax, 42nd edition,
Taxmann Publication Pvt. Ltd., New Delhi (2012-13). ™

 Ahuja, Dr. Girish & Gupta, Dr. Ravi; Taxation of Capital Gain, 7th edn., Bharat
Puplication, New Delhi (2014). ™

 Rajaratnam, S.; MAT, 8th edn., Snow White Publication, Mumbai (2013-14). ™

 Chaturvedi, K. & Pithisaria, S.M.; Companion to chaturvedi & pithisaria’s Income Tax
Law, 5th edition, Vol. 6A (1) & (2), Lexis Nexis Butterworths Wadhwa, Nagpur
(2015).™

 Rajratnam, S.(Rev.); Sampath Iyengar’s Law of Income Tax, 10th edn., Vol. 1-8, Bharat
Publication, New Delhi (2010).
Session Plan

Lectu Topics Case/ Exercise Readings

re
plan

S.
No.
Of
Class

1. Overview/Introd Maharaja Chintamani Saran Nath Sah Deo v. CIT, Text Book -
uction of the [1982] 133 ITR 658 Vol. 1,
Direct taxation Chapter No.
system in India, -1

Concept of
Capital Receipt
& Revenue
Receipts

2. Basic concepts Raghuvanshi Mills Ltd. V. CIT, (1952) 22 ITR 484 Text Book -
and Definitions (SC); Vol. 1,
under Income Chapter No.
CIT v. Sitaldas Tirathdas, (1961) 41 ITR 367 (SC)
Tax Act: India, –1
Person & Tata Teleservices Ltd. V CBDT [2016] 240 Taxman
Association of 182 (Delhi)
Persons,
Assessee,
Assessment
year, Previous
year, Finance
 Act

3. Concepts: CIT v. Sunil j. Kinariwala, (2003) 179 CTR. (SC) 15; Text Book -
Income, Vol. 1,
Brahm Datt v. Asst. CIT [2019] 260 Taxman 380
Residential Chapter No.
Status –1

4. Concept of Provincial Superior v UOI [2021] 438 ITR 548 Text Book -
Charge in (Kerala) Vol. 1,
Income Tax Chapter No.
(Section 4) –1

5. The Concept of CIT v. Mussadilal Rambharose, AIR 1987 SC 814 Text Book -
Total Income Vol. 1,
Chapter No.
–2

6. The Scope of Volkswagen Finance (P.) Ltd. V. ITO (2020) 79 ITR Text Book -
Total Income (T) 447 (Mumbai Tribunal) Vol. 1,
(Section 5) Chapter No.
–2&3

7. Residence of V.V.R.N.M. Subayyachettiar v. C.I.T., [1951] 019 ITR Text Book -

Taxable Entities 0168 (SC); Vol. 1,
(Section 6) Narottam and Parekh ltd. v. C.I.T., (1953) 55 Chapter No.
BOMLR 790; –2

CIT v. Suresh Nanda [2015] 375 ITR 172 (Del).

8. Income received M/S Chelmsford Club v. CIT, (2002) 243 ITR 89 Text Book -
or Deemed to be (SC) Vol. 1,
Received Chapter No.
(Section 7) –2

9. Income deemed Performing Right Society Ltd. V. CIT [1977] 106 ITR Text Book -
 to accrue or 11 (SC); Vol. 1,
arise in India Chapter No.
Barendra Pd. Ray v. ITO (1981) 6 Taxman 19 (SC).
(Section 9) –2
Pfizer Corporation v. CIT [2003] 129 Taxman 459
(Bom)

10. Heads of CIT v. Poddar Cement P. Ltd. (1997) 226 ITR 625 Text Book -
Income Tax (SC) Vol. 1,
(Section 14) Chapter No.
–2

11. Heads of Surya Roshni v. EPFO, 2019 LLR 339; Text Book -
Income Tax Vol. 1,
UOI v. Society of Mary Immaculate (Tamil Nadu),
(Section 14) Chapter No.
Madras (2019) 103 taxmann.com 336
–2

12. Income under Ram Prasad v. C.I.T., (1972)86 ITR 122 (SC); Text Book -
the Head Vol. 1,
Hosmat Hospital P. Ltd. V. Asst. CIT (2016) 73
Salaries – Chapter No.
taxman.com 147;
Meaning, –4
Computation & ITC Hotels v. CIT (2016) 68 taxmann.com 323
TDS

13. Tax on Text Book -

employment & Vol. 1,
treatment of Chapter No.
entertainment –4
allowance

14. Treatment of Bajrang Pd. Ramdharani v. ACIT (2013) 37 Text Book -

House Rent taxmann.com 186 Vol. 1,
Allowance Chapter No.
–4
15. Tax Treatment Text Book -
of Retirement Vol. 1,
Benefits Chapter No.
–4

16. Tax on C.I.T. v. L.W. Russel, AIR 1965 SC 49; Text Book -
perquisites – I Vol. 1,
Chapter No.
–4

17. Tax on CIT v. Mahindra & Mahindra Ltd. (2018) 93 Text Book -
Perquisites - II taxmann.com 32 (SC); Vol. 1,
Chapter No.
CIT v. Calcutta Export Company, (2018) 93
–4
taxmann.com 51 (SC)

18. Profits in Lieu Text Book -

of Salary Vol. 1,
(Section 17 (3)) Chapter No.
–4

19. Income from CIT v. Kaniyalal Nimani (1979) 120 ITR 892 (Cal.); Text Book -
House Property Vol. 1,
M. Ramalakshmi Reddi v. CIT [1998] 100 Taxman
- Chargeability Chapter No.
509
–5

20. Annual Value of CIT v. Parbutty Churn Law [1965] 57 ITR 609 Text Book -
the Property (Cal.); Vol. 1,
(Section 23) Chapter No.
D.R. Sunder raj v. CIT (1979) 2 Taxman 458
–5

21. Cases of Text Book -

Composite Rent Vol. 1,
Chapter No.
–5
22. Treatment of Text Book -
Unrealized Rent Vol. 1,
Chapter No.
–5

23. Deduction under CIT v. Veerabhadra Industries [1999] 106 Taxman Text Book -
Income from 370 Vol. 1,
House Property Chapter No.
(Section 24) –5

24. Subsequent Text Book -

Recovery of Vol. 1,
Unrealized Rent Chapter No.
(Section 25AA) –5

25. Special Text Book -

Provisions for Vol. 1,
arrears of rent Chapter No.
received –5
(Section 25B)

26. Property owned Text Book -

by Co-owners Vol. 1,
(Section 26) Chapter No.
–5

27. Deemed Owners Text Book -

(Section 27) Vol. 1,
Chapter No.
–5

28. Income under Manohar Singh v CIT (1965) 58 ITR 592 (Pun & Text Book -
the head Har) Vol. 1,
 Business and Chapter No.
Profession – –6
Capital
Expenditure and
Revenue
Expenditure

29. Capital Receipt Raja J. Rameshwar Rao v. CIT (1961) 42 ITR 179 Text Book -
v. Business (SC) Vol. 1,
Receipt & Chapter No.
Business v. –6
Profession

30. Chargeability & ACIT v. Sharukh Khan (2017) 84 Taxman.com 209 Text Book -
Scope as Income Vol. 1,
(Section 28) Chapter No.
–6

31. Rent, Rates, Ms. Priyanka Chopra v. Dy. CIT (2018) 89 Text Book -
taxes, Repairs Taxman.com 286 Vol. 1,
and insurance of Chapter No.
Buildings - (Sec. –6
30)
32. Repairs and Whittle Anderson Ltd. v. CIT, (1971) 79 ITR 613 Text Book -
insurance of (Bom.) Vol. 1,
Machinery, Chapter No.
Plant and –6
Furniture - (Sec.
31)

33. Site Restoration Text Book -

Fund - Sec. 33 Vol. 1,
ABA Chapter No.
 –6

34. Expenses on Text Book -

Amalgamation - Vol. 1,
(Sec. 35 DD) Chapter No.
–6

35. Expenses on Text Book -

VRS Vol. 1,
Compensation - Chapter No.
(Sec. 35 DDA) –6

36. Depreciation Text Book -

(Section 32) – I Vol. 1,
Chapter No.
–6

37. Depreciation – Text Book -

II Vol. 1,
Chapter No.
–6

38. Expenses on Text Book -

Scientific Vol. 1,
Research - (Sec. Chapter No.
35) –6

39. Income under Text Book -

the head capital Vol. 1,
gains – Basis of Chapter No.
Charge –7

40. Concepts I – CIT v. H.H. Maharani Usha Devi [1998] 98 Taxman Text Book -
Capital Asset & 309; Vol. 1,
Transfer Chapter No.
 CIT v. Gemini Pictures Circuit (P.) ltd. [1996] 85 – 7
Taxman 594

RasiklalChmanlal Nagri v. CWT (1965) 56 ITR 608

(Guj.)

N. Bagavathy Ammal v. C.I.T. Jt., (2003) 23 SITC

317 (SC)

41. Concepts II– Text Book -

Short Term Vol. 1,
Capital Asset & Chapter No.
Long Term –7
Capital Asset

42. What are not CIT v. G. Narasimhan (1999) 102 Taxman 66 (SC) Text Book -
Transfers Vol. 1,
Pr. CIT v. Chuni Lal Bhagat [2019] 103
(Section 47) Chapter No.
Taxmann.com 379 (SC)
–7

43. Computation of CIT v. Rasiklal Maneklal (HUF) (1989) 43 Taxman Text Book -
Capital Gains 259 Vol. 1,
(Section 48) Chapter No.
–7

44. Income under Jay Metal Industries (P.) Ltd. v. CIT (2017) 84 Text Book -
the head Taxman.com 11; Vol. 1,
‘Income from Chapter No.
M.K. Dar v. CIT (1982) 8 Taxman 176
other sources’ –8

45. Treatment of Commissioner of Income tax v. G. R. Karthikeyan, Text Book -

winning of 1993 SCR (3) 328; Vol. 1,
lotteries, games, Chapter No.
cross word –8
puzzles, horse
 races, card
games etc.

46. Tax treatment of Text Book -

dividends, Vol. 1,
interest on Chapter No.
securities –8

47. Computing CIT v. Express Newspapers Ltd., AIR 1965 SC 33; Text Book -
income from Vol. 1,
CIT v. Bokaro Steel Ltd. (1999) 102 Taxman 94.
machinery, plant Chapter No.
or furniture let –8
on hire

48. Computation of Text Book -

income from Vol. 1,
composite Chapter No.
letting of –8
building,
machinery, plant
or furniture

49. Permissible Express Newspapers (P.) Ltd. v. CIT [1997] 92 Text Book -
Deductions taxman 496; Vol. 1,
Chapter No.
–8

50. Agricultural Bacha f. Guzdar v. Comm. of Income Tax, 1955 SCR Text Book -
Income (Section (1) 876; Vol. 2,
2 (1A)) - I Chapter No.
Premier construction co. Ltd. v. C.I.T., Bombay City;
– 13
(1948) 16. ITR 380;

C.I.T.. v. Raja Benoy Kumar Sahas Roy, [1957) 32

 ITR 466,

51. Agricultural C.I.T. Poona v. H. G. Date, (1971) 082 ITR 0071 Text Book -
Income - II (Bom) Vol. 2,
Chapter No.
K. Lakshmanan & co. v. C.I.T., (1999) 239 ITR
– 13
597(SC)

52. Exemptions on C.I.T. v. Maddi Venkatasubbaya, (1983) 144 ITR 373 Text Book -
Agricultural (AP); Vol. 2,
Income (Section Chapter No.
10 (1)) – 13

53. Tax Text Book -

Administration Vol. 2,
& adjudication Chapter No.
in India – An – 33
Overview

54. Tax Authorities Text Book -

in India Vol. 2,
Chapter No.
– 33

55. Gender & Tax  Gender equality and taxation in India: An

laws unequal burden?, , TAX. GEND. EQUITY

122–146 (2010),
https://www.taylorfrancis.com/chapters/edit/1
0.4324/9780203852958-12/gender-equality-
taxation-india-unequal-burden-pinaki-
chakraborty-lekha-chakraborty
 Edward J. McCaffery, Slouching Towards
Equality: Gender Discrimination, Market
Efficiency, and Social Change (1993),
 https://papers.ssrn.com/abstract=3684003 (last
visited Jul 16, 2023).
56. Tax and
Environment
57. Ethical Association of Old Settlers of Sikkim v. Union of
Considerations in India, 2023 SCC OnLine SC 38
Tax Practice

58. Appeals & Text Book -

Revisions in Tax Vol. 2,
Matters – I Chapter No.
– 30

59. Appeals and Text Book -

Revisions in Vol. 2,
Taxation Matters Chapter No.
– II – 30

60. Penalties and Text Book -

Prosecutions Vol. 2,
Chapter No.
– 31

61. Transfer Pricing SAP Labs India Pvt. Ltd. v. ITO, Bangalore, Civil Text Book -
Norms in India – Appeal No. 8463 of 2022 Vol. 2,
I Chapter No.
– 36

62. Transfer Pricing DIT, International Taxation, Mumbai v. Morgan Text Book -
Norms in India - Stanley & Co. Inc., [Civil Appeal No. 2914 of 2007 Vol. 2,
II (arising out of S.L.P. (C) No. 12907 of 2006) and Chapter No.
Civil Appeal No. 2915 of 2007 (arising out of S.L.P. – 36
(C) No. 16163 of 2006)].
63. Tax Planning & Azaadi Bachao Andolan v. UOI, (2003) 263 ITR 706 Text Book -
Tax Avoidance (SC); Vol. 2,
Chapter No.
Vodafone International Holdings B.V. V. Union Of
– 35
India &Anr.; [2012] 1 S.C.R. 573

64. Tax Evasion McDowell & Co. Ltd. v. CTO, (1985) 3 SCC 230 Text Book -
Vol. 2,
Chapter No.
– 35

Text Book:

Commercials’ Concise Commentary on Income Tax, 24th Edn. – 2023 (Commercial Law
Publisher India Pvt. Ltd.).