Month: June 2019

Archive for June, 2019


Awanindra Singh v. DCIT (2019) 176 ITD 355/180 DTR 17 (Delhi)(Trib.)

S. 69 : Unexplained investments-FDRs found from premises of director–Reflected in the accounts of the company–Addition cannot be made as unexplained investments.

Flourish Builders & Developers (P.) Ltd. v. DCIT (2019) 176 ITD 409 (Delhi)(Trib.)

S. 68 : Cash credits-Share application money–Balance sheet, profile, bank statements and PAN details of subscriber companies were provided – Addition cannot be made as cash credits. [S. 133(6)]

ACIT v. Enterprises Business Solutions (P.) Ltd. (2019) 176 ITD 324/ 200 TTJ 268 / 179 DTR 321 (Asr.)(Trib.)

S. 56 : Income from other sources–Share premium-Fair market value of shares (FMV)- Discounted Cash Flow (DCF)–Book value- Consistently followed the method valuing the shares at discounted cash flow- Share premium cannot be taxed -Addition is deleted. [S. 56(2)(viib), R.11UA]

Sabita Devi Agarwal (Smt.) v. ITO (2019) 69 ITR 231 (Kol.)(Trib.)

S. 54F : Capital gains-Investment in a residential house–Full value of consideration-No requirement that sale proceeds alone is to be utilised for making deposit in capital gains scheme-Only one house property as on date of sale of plots-only net consideration is required to be appropriated towards purchase of new asset. [S. 45, 48, 50C]

Bal Kishan Atal. v. ACIT (2019) 176 ITD 330 (Delhi)(Trib.)

S. 54 : Capital gains-Profit on sale of property used for residence– Deposit in Capital gain account scheme-Payment to developer within prescribed time-Possession was not obtained-Consumer Redressal Commission had put stay on developer-Exemption cannot be denied-Amount deposited in capital gain account also cannot be taxed though the amount was not utilised with in specified time limit. [S. 45, 54(2)]

Rajendra Pal Verma v. ACIT (2019) 176 ITD 211/ 178 DTR 169/ 199 TTJ 873 (Mum.)(Trib.)

S. 54 : Capital gains-Profit on sale of property used for residence- -Investment in purchase of new residential property up to date of filing of his revised return- Entitle to exemption. [S. 139(5)]

Unitech Ltd. v. DCIT (2019) 176 ITD 266 (Delhi)(Trib.)

S. 45 : Capital gains-Business income-Shares held as investment–Recorded as investment in the books of account at the time of purchase and from year to year–Sale consideration cannot be assessable as business income.[S. 28(i)]

Fertilizer corporation of India Ltd. v. ACIT (2019) 69 ITR 183 (Delhi)(Trib.)

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability–Waiver of interest and LIC guarantee fee-Not claimed as deduction in earlier years-Addition cannot be made– Adjustment of carry forward of losses and depreciation-Matter remanded to CIT(A) for read judication.

Bhangal Construction Co. v. ITO (2019) 176 ITD 419 (Asr.)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source–Hiring charges for use of cranes–Payment being not contractual – Not liable to deduct tax at source. [S. 194C]

ACIT v. Arihant Trading Co. (2019) 176 ITD 397 (Jaipur) (Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Contractor-PAN of transporters at time of payment of freight was collected–Disallowance cannot be made. [S. 194C(6), 194C(7)]