This compilation indexes 12 rulings — from various benches of the Income Tax Appellate Tribunal (ITAT) and several High Courts — in which Section 135 of the relevant statute appears alongside other provisions including Section 80G, Section 263, Section 37(1), and related procedural sections. The compilation spans orders pronounced between November 2025 and September 2026 and is intended for use by in-house tax teams, Big-4 associates, and law firm researchers as a structured reference index. Each entry records the bench, date, sections engaged, outcome direction, and a brief procedural note drawn exclusively from the source preview of that case.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers should verify each ruling against the full authenticated judgment before placing reliance on it.

The statutory framework in one paragraph

Section 135 of the Income Tax Act, 1961 imposes an obligation on certain companies to spend on Corporate Social Responsibility (CSR) activities as specified under the Companies Act, 2013, and intersects with the income-tax framework particularly in the context of the deductibility of such expenditure under Section 37(1) and the eligibility of donations for deduction under Section 80G. The section is frequently cited alongside Section 80G — which governs deductions in respect of donations to certain funds, charitable institutions, and other entities — in assessment, revisionary, and appellate proceedings where the allowability or disallowability of related expenditure or donations is in dispute. It also appears in non-income-tax statutory contexts (municipal, electricity, and criminal law) where "Section 135" refers to provisions of other enactments, as reflected in several rulings in this compilation.

The 12 rulings

1. Antelopus Selan Energy Limited vs DCIT Circle - 22 (2) , Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 10 September 2026
Sections engaged: 135, 37(1), 80G, 80G(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.5860/DEL/2026) arises from an order dated 09.04.2026 passed under Section 250 of the Income Tax Act, 1961 by the National Faceless Appeal Centre (NFAC), for Assessment Year 2020-21. Per the source preview, the assessee — engaged in oil and gas production since 1995 — filed its original return of income for AY 2020-21 declaring total income at Rs.53,30,30,480/-, and during assessment proceedings the Assessing Officer observed that the assessee had incurred expenses amounting to Rs.70,50,000, with the dispute engaging Sections 37(1), 80G, and 80G(2)(a) alongside Section 135.

2. Icore Super Cement Pvt. Ltd. Through vs U.P.P.C.L. Through Chairman And 3

Bench: Allahabad High Court
Date: 3 September 2026
Sections engaged: 135, 152
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as Writ-C No. 70125 of 2013 before the Allahabad High Court, reserved on 15.07.2026 and delivered on 03.09.2026, along with four connected writ petitions filed by other cement and polytex companies against U.P.P.C.L. The source preview is procedural in nature and does not disclose the substantive merits adjudicated; the appeal was filed and decided in the context of the sections listed above.

3. Juniper Networks India Private vs Principal Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 3 September 2026
Sections engaged: 135, 142(1), 143(3), 144C(3), 263, 37(1), 80G
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 6137/MUM/2026) for A.Y. 2020-21 challenges the assumption of revisionary jurisdiction under Section 263 of the Income Tax Act, 1961 by the Principal Commissioner of Income Tax (Central), Mumbai-1, and the consequential setting aside of the assessment order dated 30.09.2023 passed under Section 143(3) read with Section 144C(3), on the issue of a deduction allowed — the source preview indicates the deduction related to provisions engaged by Sections 37(1) and 80G. The hearing and pronouncement both occurred on 03.09.2026.

4. Prakash Nandedkar vs Indore Municipal Corporation Indore

Bench: Madhya Pradesh High Court
Date: 1 September 2026
Sections engaged: 135, 136(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (WP-35196-2026) was filed under Article 226 of the Constitution of India before the Madhya Pradesh High Court at Indore, seeking assessment of property tax in accordance with law after granting applicable exemptions under Section 136(c) of the Madhya Pradesh Municipal Corporation Act, 1956, and a direction for refund of Rs.1,00,000/- deposited by the petitioner in compliance with an earlier order dated 24/04/2026 along with interest. The source preview is procedural and does not disclose the final substantive ruling.

5. Blueberry Trading Company Private vs The Principal Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 31 August 2026
Sections engaged: 135, 143(1), 143(3), 144B, 263, 80, 80G
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 6032/MUM/2026) for Assessment Year 2022-23 was filed by Blueberry Trading Company Private Limited (PAN: AABCB5512E) before the Mumbai Bench of the ITAT against the Principal Commissioner of Income Tax (PCIT), Mumbai-6; the hearing concluded on 18-Aug-2026 and the order was pronounced on 31-08-2026. The source preview is largely procedural and caption-level; the sections engaged include Section 263 revisionary jurisdiction alongside Section 80G and related assessment provisions, but the substantive ground of the ruling is not elaborated in the available preview.

6. Natco Pharma Limited,Hyderabad vs ACIT, Circle -5(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 21 August 2026
Sections engaged: 80G, 135
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 640/Hyd/2026) for Assessment Year 2022-23 was filed by NATCO Pharma Ltd (PAN: AAACN6927A), Hyderabad, feeling aggrieved by the final assessment order passed by the Assessing Officer dated 24.12.2025 under Section 143(3) read with Sections 144C(13) and 144B of the Income Tax Act, 1961. The hearing was on 06/08/2026 and the order was pronounced on 21/08/2026; the source preview does not set out the substantive ground resolved beyond identifying the sections engaged.

7. Shalby Limited,Ahmedabad, Gujarat vs DCIT ,Cir-4(1)(1),Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 21 July 2026
Sections engaged: 80G, 135
Outcome: Outcome not specified in source
Procedural / substantive ground: The ITAT Ahmedabad "C" Bench heard two appeals (ITA Nos. 1492 & 1474/Ahd/2026) for Assessment Years 2022-23 and 2023-24 by Shalby Limited (PAN: AAICS5593B), heard on 10.06.2026 and pronounced on 21.07.2026. Per the source preview, since the issues in both appeals were common and identical, they were heard together and disposed of by a consolidated order, with ITA No.1492/Ahd/2026 for AY 2022-23 treated as the lead case and the decision therein applied to the connected appeal.

8. Schneider Electric It Business India vs Deputy Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 8 June 2026
Sections engaged: 80G, 135
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.: 1585/Bang/2024) for Assessment Year 2020-21 was filed by Schneider Electric IT Business India Private Limited (PAN: AACCA6398Q) against the final assessment order dated 26.07.2024 passed under Section 143(3) read with Sections 144C(13) and 144B of the Income Tax Act, 1961, pursuant to directions dated 26.06.2024 issued by the Dispute Resolution Panel-2, Bengaluru; the appeal was listed for hearing before the bench pursuant to a common order dated 01.06.2026, with the hearing on 04-06-2026 and pronouncement on 08-06-2026.

9. Rattan Singh vs State Of Haryana And Ors

Bench: Punjab-Haryana High Court
Date: 13 March 2026
Sections engaged: 135, 145, 153
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (CWP-35731-2025) was decided on 13.03.2026 by the Punjab-Haryana High Court at Chandigarh along with three connected writ petitions filed by other petitioners (CWP-7159-2026, CWP-6961-2026, CWP-7396-2026) against the State of Haryana and Dakshin Haryana Bijli Vitran Nigam Limited (DHBVN). The source preview is procedural in nature, listing the parties and coram, and does not elaborate the substantive merits resolved in the ruling beyond the sections cited.

10. Shri Samir Ranjan Barman vs The Agartala Municipal Corporation

Bench: Tripura High Court
Date: 10 March 2026
Sections engaged: 135
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ appeal (W.A. No.52 of 2025) was filed before the High Court of Tripura at Agartala by Shri Samir Ranjan Barman against the Agartala Municipal Corporation and related respondents; the judgment and order is dated 10.03.2026 and was marked fit for reporting. The source preview is introductory and does not disclose the substantive ground adjudicated; the appeal arose in the context of proceedings before the Agartala Municipal Corporation.

11. S.D.O. Op. Sub Division, Dhbvn And Anr vs Ramphal

Bench: Punjab-Haryana High Court
Date: 18 February 2026
Sections engaged: 135, 152, 153
Outcome: Outcome not specified in source
Procedural / substantive ground: This second appeal (RSA-3009-2024) was filed by the defendants (S.D.O., Op. Sub Division, DHBVN and another) before the Punjab-Haryana High Court at Chandigarh, aggrieved by the judgment and decree passed by the courts below, decided on 18.02.2026. Per the source preview, the plaintiff was a consumer of the defendant-Nigam who regularly paid electricity bills; the defendants prepared a checking report dated 26.01.2019 alleging theft of electricity and issued two memos dated 07.02.2019 assessing a penalty of Rs.1,38,263/- and compounding charges of Rs.40,000/-, and the plaintiff asserted that no prior notice was issued as required under electricity rules.

12. Maneklal Ravjibhai Mistry vs State Of Gujarat

Bench: Gujarat High Court
Date: 14 November 2025
Sections engaged: 135, 108
Outcome: Outcome not specified in source
Procedural / substantive ground: The criminal revision application (R/CR.RA/507/2003), reserved on 30.07.2025 and pronounced on 14.11.2025, was filed by the applicant (original accused) under Sections 397 and 401 of the Code of Criminal Procedure before the Gujarat High Court at Ahmedabad, directed against the judgment dated 08.10.2003 passed by the Sessions Judge, Valsad in Criminal Appeal No.9 of 2002. The source preview is introductory and does not elaborate the substantive criminal law ground resolved; the sections cited (135 and 108) appear in the context of the relevant penal or special statute invoked in that proceeding.

Patterns across these 12 rulings

Section 135 as a co-citation across diverse legal contexts. Across this set of rulings, Section 135 appears as a co-cited provision alongside income-tax sections (80G, 263, 37(1), 143(3), 144B, 144C) in ITAT matters, but also alongside provisions of municipal corporation acts, electricity statutes, and the Code of Criminal Procedure in High Court matters. Researchers should verify which enactment's "Section 135" is at issue in any given ruling before drawing substantive conclusions.
Section 80G deductibility as a recurring income-tax theme. Among the ITAT rulings in this compilation (cases 1, 3, 5, 6, 7, 8), Section 80G appears consistently alongside Section 135, suggesting that the allowability of donations or CSR-related expenditure under Section 80G is a recurrent issue in appeals where Section 135 is cited in the income-tax context.
Section 263 revisionary jurisdiction as a contested ground. At least two ITAT matters in this compilation (cases 3 and 5) engage Section 263 alongside Sections 143(3) and 144B/144C, indicating that revisionary proceedings initiated by the Principal Commissioner of Income Tax — and the consequential challenge to the assumption of jurisdiction under Section 263 — represent a recurring procedural battleground for AY 2020-21 and AY 2022-23.
Consolidated disposal of linked appeals. In at least one case in this compilation (case 7), the ITAT disposed of two appeals for different assessment years by a single consolidated order, treating one as the lead case, a procedural approach that researchers tracking multi-year disputes should note when searching for orders.
Outcome direction uniformly unavailable in source. Across all 12 rulings in this compilation, the outcome direction is recorded as "Outcome not specified in source." Researchers must access the full authenticated judgments to ascertain the final holding, relief granted, or directions issued by the respective forum.

How to use this compilation

This compilation is structured as a research index and is intended to assist in identifying relevant rulings for further investigation. Each entry provides the tribunal or court, the date of pronouncement, the sections engaged, and a brief procedural note drawn from the available source preview. Because outcome directions are not available in the source data for any of the 12 rulings listed, researchers must retrieve and review the full authenticated text of each judgment from the official court portal, the Income Tax Appellate Tribunal's website, or indiankanoon.org before placing any reliance on the ruling in a matter.

Researchers should also verify whether any of the rulings listed have been subsequently stayed, reversed, modified, or appealed to a higher forum. An ITAT order may be challenged before the relevant High Court under Section 260A of the Income Tax Act, 1961, and a High Court ruling may be further appealed to the Supreme Court; the absence of any such information in this compilation does not confirm that a ruling is final or undisturbed. Similarly, where a ruling is one in a batch of connected cases, researchers should check whether the consolidated disposal covers all batch members or only specified ones.

Finally, where Section 135 in a given ruling appears to refer to a provision of a statute other than the Income Tax Act, 1961 (as is the case for several High Court matters in this compilation involving municipal corporation law, electricity law, or criminal procedure), researchers should confirm the governing enactment before treating the ruling as income-tax precedent. Cross-regime citation indexing can produce apparent matches that are substantively inapplicable to an income-tax research question.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 80G & 135: 12 ITAT and High Court Rulings (2025-2026)