Month: November 2018

Archive for November, 2018


ITO v. Nita Narendra Mulani. (Smt.) (2018) 172 ITD 169 (Mum) (Trib.)

S. 48 : Capital gains – Computation – Indexation -Asset acquired under a gift, indexed cost of acquisition of such capital asset has to be computed with reference to year in which previous owner first held asset. [ S.45 ]

ACIT v. Apurva Mahesh Shah. (2018) 172 ITD 127 (Mum) (Trib.)

S. 48 : Capital gains – Computation – Short term capital gain- Performance linked fees and portfolio management fees paid to portfolio manager is not allowable as deduction .[ S.45 ]

Het Ram Sharma. v. ITO (2018) 172 ITD 324 (Chd) (Trib.)

S.45: Capital gains- Land -On acquisition of land on which there was a hotel, part of compensation related to land would be subject to Long term capital gains and that on hotel building assessable as short term capital gains. [ S.54 ]

DCIT v. Arjun Puri. (2018) 66 ITR 33 / 172 ITD 29 (Delhi) (Trib.)

S.45: Capital gains- Business income- Co -owner –land as investment -One of the Co -0wener showing the land as stock in trade -Profit on sale of share is assessable as capital gains and not as business income .[ S.28(i) ,54F ]

ITD Cem India JV v. ACIT (2018) 172 ITD 313/(2019) 180 DTR 13/ 200 TTJ 913 (Mum) (Trib.)

S. 40(ba) : Amounts not deductible – Association of persons – Amount paid to member as reimbursement- In order to invoke provisions payments should constitute share income from AOP in hands of recipient member. [ S.67A ]

DCIT v. Esaote India (NS) Ltd. (2018) 172 ITD 299 / 172 DTR 427(/ 196 TTJ 1091 Ahd) (Trib.)

S. 40(a)(ia): Amounts not deductible – Deduction at source -Interest- Where recipient/deductee had already paid tax on impugned amount of interest under section 194A received from assessee by filing return of income, such interest payment could not be disallowed – Second Proviso to section 40(a)(ia) has retrospective effect from 1-4-2005 [ S.194A , 195(3) . 201(1) ]

K.V. Satyanarayana Murthy. v. ITO (2018) 172 ITD 7 (Visakha) (Trib.)

S. 40(a)(ia): Amounts not deductible – Deduction at source – Supplier transported goods to assessee through their own transport agency-there was no contract between assessee and transporter- Not liable to deduct tax at source .[ S.194C]

DCIT v. Esaote India (NS) Ltd. (2018) 172 ITD 299/ 172 DTR 427/ 196 TTJ 1091 (Ahd) (Trib.)

S.37(1):Business expenditure -Sales promotion expenses- supply of certain products free of cost to Government hospitals and other hospitals in pursuance of purchase order placed by such hospitals- Allowable as business expenditure – Circular No 5/2012 dt. 1-8-2012 (2012) 346 ITR 95 (St) is prospective in nature .

Loesche India (P.) Ltd. v. ACIT (2018) 172 ITD 176 / 195 TTJ 33 (UR)(Delhi) (Trib.)

S.37(1): Business expenditure- Insurance premiums of employees’ family members in terms of employment rules framed by assessee-company –Allowable as business expenditure. [ S.17 (2)(iv) ]

Fincity Investments (P.) Ltd. v. ACIT (2018) 172 ITD 204/ 172 DTR 396 (Hyd) (Trib.) Veeyes Investments ( P) Ltd v. ACIT ( 2018) 172 ITD 218 /( 2019) 197 TTJ 261/ 175 DTR 109(Hyd) (Trib)

S.37(1):Business expenditure- Service charges paid to SRSR Advisory Services Pvt Ltd for advisory services in assessee business area, accounting services, collection of interest and dividend, taxation, ROC related matters and maintenance of its land properties etc.- Allowable as business expenditure .