Year: 2018

Archive for 2018


Seema Sabharwal v. ITO (2018) 169 ITD 319/ 193 TTJ 128/ 163 DTR 253 (Chd)(Trib) , www.itatonline.org

S. 54: Capital gains – Profit on sale of property used for residence – If entire consideration was paid with in three years the assessee is entitle to exemption [ S.45, 54F ]

ITO v. Southern Steel Ltd. (2018) 61 ITR 126 (Hyd) (Trib)

S. 50C : Capital gains – Full value of consideration – Stamp valuation – Distress sale -Transactions between Government entities, provision cannot be applied . [ S. 45 ]

JCIT v. D. Sesha Giri Rao. (2018) 168 ITD 287 (Hyd) (Trib.)

S. 50C : Capital gains – Full value of consideration – Stamp valuation -Assessee was not a real owner of property and he transferred same on representative basis, provisions of section 50C could not be applied to assessee’s case in order to compute capital gain arising from sale of said property [ S.45 ]

L & T Finance Ltd. v. DCIT (2018) 168 ITD 52 (Mum) (Trib.)

S. 50B : Capital gains – Slump sale –Transfer of individual assets to sister concern without transfer of undertaking or business activity as a whole cannot be considered as slump sale [ S. 2(19AA), 2(42C ) ]

Emami Infrastructure Ltd. v. ITO (Kol)(Trib) , www.itatonline.org

S. 47(iv) : Capital gains – Transaction not regarded as transfer – Subsidiary – A subsidiary of a subsidiary (step-down subsidiary) is also a subsidiary of the parent. Consequently, transfers between the holding company and the step-down subsidiary are not “transfers” which can give rise to capital gains or loss. [ S.45 , 48, Companies Act , S. 4(1)( c ), 108 ]

Mahul Construction Corporation. v. ITO (2018) 168 ITD 120/ 164 DTR 217/ 193 TTJ 8 (Mum) (Trib.)

S. 45(4) : Capital gains – Distribution of capital asset – Revaluation of assets on retirement – On retirement the accounts are settled of retiring partners without distribution of capital assets , provisions of S. 45(4) cannot be invoked.Capital gains cannot be levied on the firm [ S. 2(47),45 ]

ITO v. Dr. Arvind Goverdhan. (2018) 61 ITR 159 (Bang) (Trib) ITO v. Monica Goverdhan ( Mrs) (2018) 61 ITR 159 (Bang) (Trib) ITO v Margrift Goverdhan( Mrs) (2018) 61 ITR 159 (Bang) (Trib) ITO v. Anitha Goverdhn ( Mrs) (2018) 61 ITR 159 (Bang) (Trib)

S. 45:Capital gains — Transfer — Development agreement- Capital gains is taxable in the year in which possession was handed over and not in the year in which the project was completed [ S. 54, 54F ]

Meenu Goel v. ITO( SMC) (Delhi)(Trib) , www.itatonline.org

S. 45: Capital gains- Cash credits- Penny stocks – When the identity and genuineness of transaction is established merely because , the investigation department has alleged that there is a modus operandi of bogus Long term capital gains scheme is not relevant if the same is not substantiated [ S.10(38), 68 ]

DCIT v. Alcon Biosciences P. Ltd( 2018) 164 DTR 193/193 TTJ 1 (Mum)(Trib) , www.itatonline.org

S. 45: Capital gains-Cash credits- Share capital-Shares were issued at premium- Identity and PAN was furnished addition cannot be made as undisclosed income . [ S. 68, 133(6) ]

Madhu Sarda v. ITO (Mum)(Trib) , www.itatonline.org

S. 45: Capital gains- Set off of capital loss-Sham transaction”/ “Colourable device”- Sale of shares to son cannot be held to held to be colourable device if the transaction is with in the four corners of law and valid