This compilation indexes twelve Indian court and tribunal rulings — spanning the Supreme Court of India, multiple High Courts, and ITAT benches — in which Section 45 of the relevant statute was a cited provision. The rulings cover the period July 2025 to May 2026. Researchers should note that "Section 45" appears across different legislative instruments in this dataset: Section 45 of the Income Tax Act, 1961 (charging section for capital gains) features prominently in the ITAT and Bombay High Court matters, while Section 45 of the Prevention of Money Laundering Act, 2002 (bail conditions) is central to several High Court criminal matters. Each case entry identifies the precise statutory context per the source data.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or professional opinion of any kind. Readers should consult the full text of each judgment and seek qualified professional counsel before acting on any matter.

The statutory framework in one paragraph

Section 45 of the Income Tax Act, 1961 is the charging provision for capital gains: it provides that any profits or gains arising from the transfer of a capital asset effected in the previous year shall be chargeable to income-tax under the head "Capital Gains" and shall be deemed to be the income of the previous year in which the transfer took place. The section must be read alongside the definition of "transfer" in Section 2(47) — including clause (v), which extends the meaning of transfer to cover transactions such as part-performance of a contract under the Transfer of Property Act — and alongside the computation provisions in Sections 48 and 49. In a separate legislative context, Section 45 of the Prevention of Money Laundering Act, 2002 sets out the twin conditions that a court must be satisfied with before granting bail to a person accused of an offence under that Act; several rulings in this compilation arise under that provision rather than under the Income Tax Act.

The 12 rulings

1. Manjula vs D.A. Srinivas

Bench: Supreme Court of India
Date: 8 May 2026
Sections engaged: 2(9), 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This Civil Appeal (No. 7370 of 2026, arising out of SLP (C) No. 7924 of 2024) was filed before the Supreme Court against a judgment and final order dated 22.02.2024 passed by the High Court of Karnataka at Bengaluru in Regular First Appeal No. 2216 of 2023. Per the source preview, the judgment addresses issues including the rejection of plaint, conducting suits under the CPC, whether a suit is barred by law under the Prohibition of Benami Property Transactions Act and its 2016 Amendment, the prospective or retrospective operation of the 2016 Amendment, and fiduciary capacity and exemption thereunder; the substantive merits of the Supreme Court's disposal are not reproduced in the available source preview.

2. Raju Kumar Yadav ,Patna vs Income Tax Officer Ward 6(4) Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 24 April 2026
Sections engaged: 147, 45A, 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 588/PAT/2025) for Assessment Year 2016-2017 was filed by the assessee (PAN: BJRPR8285D) before the ITAT SMC Bench, Patna (Virtual Hearing at Kolkata) against the order passed under Section 250 of the Income Tax Act, 1961 by the Addl./Joint Commissioner of Income Tax (Appeals)-1, Chennai dated 10.10.2025. Per the source preview, one of the grounds raised was that income from a project was taxed in the wrong assessment year because the construction of the project was not complete and continued to remain incomplete as on the date of the appeal, and that there was no ascertainable consideration; the tribunal's final disposal is not reproduced in the available source preview.

3. Central Bureau Of Investigation vs Kuldeep Singh & Ors

Bench: Delhi High Court
Date: 20 April 2026
Sections engaged: 19, 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (CRL.REV.P. 134/2026 & CRL.M.A. 6853/2026) was heard by the Delhi High Court, with the judgment reserved on 13.04.2026 and pronounced on 20.04.2026. Per the source preview, the petition was filed by the Central Bureau of Investigation; the source preview is largely procedural, listing the appearances of counsel and parties, and the substantive ground and outcome of the criminal revision petition are not reproduced in the available extract.

4. Pancham Singh,Patna vs ITO, Ward- 6 (3), Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 16 March 2026
Sections engaged: 2(47)(v), 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 462/Pat/2025) for Assessment Year 2014-15 was filed before the ITAT Patna Bench (Virtual Bench at Kolkata) by the assessee (PAN: LASPS3469J), an individual who had not filed a return of income for A.Y. 2014-15. Per the source preview, the Assessing Officer had information that the appellant had entered into a Land Development Agreement (LDA) with M/s Sehra Real Estate Pvt. Ltd. on 27/08/2013 for the development of his immovable property situated at Mauja Rukanpura, Thana No. 5, Circle Danapur, Patna, measuring approximately 7,405.2 sq. ft.; the tribunal's final disposal is not reproduced in the available source preview.

5. Niranjan Das vs Directorate Of Enforcement

Bench: Chattisgarh High Court
Date: 10 March 2026
Sections engaged: 45, 66
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (MCRC No. 1065 of 2026) was the first bail application filed by the applicant before the High Court of Chhattisgarh at Bilaspur under Section 45 of the Prevention of Money Laundering Act, 2002 read with Section 483 of the Bharatiya Nagarik Suraksha Sanhita, in connection with ECIR No. ECIR/RPZO/04/2024 dated 11.04.2024 registered by the Directorate of Enforcement for offences punishable under the PMLA. Per the source preview, the said ECIR was predicated upon FIR No. 04/2024 dated 17.01.2024 registered by ACB Raipur for offences relating to the alleged liquor scam; the court's disposal of the bail application is not reproduced in the available source preview.

6. Md. Mofazzular Rahman & Ors vs Md. Sarfaraz Alam & Ors

Bench: Calcutta High Court
Date: 10 November 2025
Sections engaged: 45, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: This application (G.A. No. 8 of 2023 in C.S. (COM) No. 158 of 2024, Old No. CS 174 of 2019) was heard before the Commercial Division of the Calcutta High Court, with hearing concluded on 17.09.2025 and judgment pronounced on 10.11.2025. Per the source preview, the defendant no. 1 filed the present application praying for recording the death of plaintiff no. 1 and to substitute the legal heirs of plaintiff no. 1 as plaintiff nos. 1A to 1F and for amendment in the written statement and counter claim; plaintiff no. 1 had died on 16th June, 2023 during the pendency of the suit. The substantive merits of the disposal are not reproduced in the available source preview.

7. Roshan Chandrakar vs Directorate Of Enforcement

Bench: Chattisgarh High Court
Date: 12 September 2025
Sections engaged: 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (MCRC No. 6581 of 2025) was the second bail application filed before the High Court of Chhattisgarh at Bilaspur under Section 45 of the PMLA, 2002 seeking regular bail in ECIR/RPZO/04/2023 dated 14.10.2023, relating to offences under the provisions of the PMLA. Per the source preview, the applicant had earlier challenged a dismissal before the Supreme Court via SLP (Crl.) No. 1216/2025, which was withdrawn on 27.01.2025 with liberty to renew the bail application; the court's disposal of the present application is not reproduced in the available source preview.

8. Manoj Kumar Babulal Punamiya vs The State Of Jharkhand Through Director

Bench: Jharkhand High Court
Date: 27 August 2025
Sections engaged: 45
Outcome: Outcome not specified in source
Procedural / substantive ground: Two connected criminal revision petitions (Criminal Revision No. 1091 of 2012 and Criminal Revision No. 1326 of 2018) were heard together before the Jharkhand High Court at Ranchi. Per the source preview, the petitioners included Manoj Kumar Babulal Punamiya in his individual capacity and as director of Balaji Lifestyle Realtors Private Limited and Balaji Universal Tradelink Private Limited, with the opposite party being the State of Jharkhand through Director of Enforcement; the substantive ground and outcome of the criminal revisions are not reproduced in the available source preview.

9. Renu Devi,Patna vs ITO, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 25 August 2025
Sections engaged: 2(47)(v), 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 672/PAT/2024) for Assessment Year 2016-2017 was filed before the ITAT Kolkata-Patna e-Court by the assessee (PAN: ALGPD4522P), an individual, against the order of the Addl./Joint Commissioner of Income Tax (Appeals)-12, Mumbai dated 25th September 2024. Per the source preview, the assessee had purchased a piece of land vide Deed No. 10701 dated 05.12.2015 for Rs. 19,23,575/- and entered into a development agreement with Aparna Architect and Engicons Pvt. Ltd. (Builder/Developer) vide Development Agreement No. 10772 on the same day; the assessee had no taxable income during A.Y. 2016-17 and accordingly no regular return was filed. The tribunal's final disposal is not reproduced in the available source preview.

10. Damayanti Ramachandran,Gn Mills Post vs Income Tax Officer, Coimbatore

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 August 2025
Sections engaged: 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was heard before the ITAT Chennai bench. Per the source preview, the matter involves changes in profit-sharing ratios in partnership firms — Texmo Industries and Texmo Precision Castings — held by the assessee Damayanthi Ramachandran (HUF) and associated trusts, along with a revaluation of M/s Texmo Industries that resulted in goodwill of Rs. 712.27 Crores being recorded (business revaluation of Rs. 901.85 Crores less book value of Rs. 189.58 Crores); the source preview also references reopening of assessments for A.Y. 2015-16 and A.Y. 2016-17 in relation to withdrawal of amounts from current accounts on account of goodwill. The tribunal's final disposal is not reproduced in the available source preview.

11. Alamgir Alam S/O Late Sanaul Haque vs The Directorate Of Enforcement

Bench: Jharkhand High Court
Date: 11 July 2025
Sections engaged: 17, 45
Outcome: Outcome not specified in source
Procedural / substantive ground: This bail application (B.A. No. 9548 of 2024) was heard before the Jharkhand High Court at Ranchi, with the matter reserved on 20.06.2025 and pronounced on 11.07.2025. Per the source preview, an ECIR bearing No. ECIR/RNSZO/16/2020 was recorded on 17.09.2020 based on FIR No. 13/2019 dated 13.11.2019, registered by ACB Jamshedpur; a charge-sheet dated 11.01.2020 was submitted by ACB against named individuals under the Prevention of Corruption Act, 2018 and under Sections 120B and 201 of the Indian Penal Code, which are scheduled offences under the PMLA. The court's disposal of the bail application is not reproduced in the available source preview.

12. Poonawalla Extates Stud And Agri vs Dy Commissioner Of

Bench: Bombay High Court
Date: 9 July 2025
Sections engaged: 41(1), 45
Outcome: Outcome not specified in source
Procedural / substantive ground: Four connected Income Tax Appeals (ITA No. 541 of 2003, ITA No. 535 of 2003, ITA No. 540 of 2003, and ITA No. 175 of 2005) pertaining to Assessment Years 1988-89, 1990-91, 1991-92, and 1995-96 respectively were heard before the Bombay High Court. Per the source preview, the Appeals were admitted by formulating a solitary question of law in each, and the source preview references specific race-horse assets including Mare 'Certainty' (Rs. 40,000/-), Mare 'Tribute' (Rs. 1,00,000/-), Stallion 'Gombos' (Rs. 1,60,902/-), and Mare 'Shrimati' (Rs. 10,000/-) with a combined value of Rs. 3,60,902/-; the substantive question of law and the court's final ruling are not fully reproduced in the available source preview.

Patterns across these 12 rulings

Development agreements and the timing of transfer under Section 2(47)(v): At least three ITAT matters in this compilation — Pancham Singh (ITA No. 462/Pat/2025, A.Y. 2014-15), Renu Devi (ITA No. 672/PAT/2024, A.Y. 2016-17), and Raju Kumar Yadav (ITA No. 588/PAT/2025, A.Y. 2016-17) — involve individuals who entered into land development agreements with builders and were assessed to capital gains by the Assessing Officer. A recurring argument visible in the previews is that income was taxed in the wrong assessment year because construction was incomplete and consideration was not ascertainable, raising contested questions about when the transfer event crystallises for charging purposes.
PMLA Section 45 bail applications constitute a significant share of the dataset: Five of the twelve matters indexed here — Niranjan Das (Chhattisgarh HC), Roshan Chandrakar (Chhattisgarh HC), Manoj Kumar Babulal Punamiya (Jharkhand HC), and Alamgir Alam (Jharkhand HC) — are bail applications under Section 45 of the Prevention of Money Laundering Act, 2002. Researchers using this index for Income Tax Act capital gains research should filter carefully by the sections_engaged field to distinguish PMLA matters from income-tax matters.
Non-filing of income tax return as a trigger for reassessment: In at least two ITAT cases in this compilation (Pancham Singh and Renu Devi), the source previews note that the assessee had not filed a return of income for the relevant assessment year, and the Assessing Officer initiated action on the basis of external information (such as a registered development agreement). This pattern suggests that detection of unregistered or undisclosed transfer transactions via registration data is a recurring trigger for capital gains assessments in this cohort.
Multi-AY and multi-appeal structures: The Bombay High Court matter involving Poonawalla Extates Stud And Agri illustrates a pattern of consolidated appeals spanning multiple assessment years (1988-89, 1990-91, 1991-92, and 1995-96) admitted on a common question of law, reflecting how legacy disputes over the character and taxability of asset disposals can remain in appellate litigation over extended periods.
Limited substantive disclosure in available source previews: Across all twelve matters, the available text_preview data is predominantly procedural — covering party names, case numbers, dates of hearing, and brief factual matrices — without reproducing the dispositive reasoning or final order. Researchers must obtain and verify the full text of each judgment before drawing substantive conclusions about the ratio or holding in any of these cases.

How to use this compilation

This index is designed to assist tax researchers, in-house counsel, Big-4 associates, and law firm professionals in identifying and locating relevant judicial proceedings involving Section 45. The appropriate first step when using any entry in this compilation is to retrieve the full text of the judgment from the official court portal, indiankanoon.org, or the ITAT e-filing portal, and to verify that the summary information here matches the original document. Source previews used to compile this index are necessarily truncated and may not reflect later corrections, corrigenda, or amplifications issued by the court.

Before relying on any ruling for a litigation or advisory purpose, researchers should check whether the decision has been the subject of an appeal, a stay, a remand, or a reversal at a higher forum. Supreme Court and High Court disposals in particular may have been appealed or may have been superseded by subsequent legislative amendments or CBDT circulars. The CBDT regularly issues instructions, clarifications, and circular amendments that can affect the application of Section 45 to specific transaction types such as joint development agreements, partial transfers, and partnership reconstitutions.

Finally, note that this compilation deliberately mixes income-tax and PMLA matters because Section 45 appears in both statutes. Researchers focused exclusively on capital gains under the Income Tax Act, 1961 should filter this index to cases where the bench is an ITAT bench or where the court_short indicates an income-tax appeal jurisdiction (such as the Bombay High Court income tax appeal numbers), and should cross-reference the sections_engaged field to confirm that Section 45 of the Income Tax Act — rather than Section 45 of the PMLA — is the operative provision in the case of interest.

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 45 Capital Gains & PMLA Bail: 12 Indian Court Rulings (2025-2026)