Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Tax & Customs LawSupreme Court of India

Pr. Commissioner of Income Tax, Shimla v. M/s. Aarham Softronics

Civil Appeal · 2019 INSC 231Decided 20 Feb 2019
Civil Appeal No. 1784 of 2019
Justice A.K. Sikri · Justice S. Abdul Nazeer · Justice M.R. Shah

Background

Several industrial units set up in Himachal Pradesh had initially claimed a 100% tax deduction under Section 80-IC of the Income Tax Act for the first five years of operation (as the law allows for new units in specified categories), after which the deduction drops to 25-30% for the remaining years of the ten-year window. These assessees later carried out "substantial expansion" of their units within that ten-year period and claimed they were entitled to the 100% deduction rate again from the year of expansion. The Himachal Pradesh High Court ruled in the assessees' favour, and the Income Tax Department (Revenue) appealed to the Supreme Court; connected appeals filed by assessees on the same point were also tagged and heard together.

Decision Breakdown

The Supreme Court held that Section 80-IC itself defines "initial assessment year" in a way that allows a unit to acquire a second "initial assessment year" if it undertakes substantial expansion within the ten-year period, distinguishing this from the differently-worded provision in Section 80-IB relied on by an earlier judgment (Classic Binding Industries), which the Court held did not correctly state the law on this point. It clarified that an eligible unit gets 100% deduction for the first five years, then a reduced rate for subsequent years until the ten-year window, but if substantial expansion occurs within that ten-year window, the year of expansion becomes a fresh "initial assessment year" restoring the 100% deduction rate for the remaining years up to the original ten-year cap (the total period of benefit being capped at ten years overall). Applying this reasoning, the Court affirmed the High Court's judgment, dismissed all the Revenue's appeals, and allowed the appeals filed by the assessees on the same issue.

Lesson Learnt

A business that qualifies for a tax holiday under Section 80-IC and later substantially expands its unit within the permitted ten-year window can regain the full 100% deduction rate for the remaining years, rather than being stuck at the lower post-five-year rate, but the total benefit period is still capped at ten years from the original start.

Pr. Commissioner of Income Tax, Shimla v. M/s. Aarham Softronics – Legal Case Shots | LegalAware