Year: 2019

Archive for 2019


Commitment Mortality Vision Education Society v. ACIT (2019) 74 ITR 62(SN) (Delhi)(Trib.)

S. 271(1)(b) : Penalty-Failure to comply with notices–Penalty is upheld based on assessee’s conduct and failure to comply with statutory notices but deleted the penalty for five years in the interest of justice. [S.132, 142(1)]

Conton Textiles Mills Pvt. Ltd. v. PCIT (2019) 55 CCH 600 / 72 ITR 85 (Delhi) (Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Share capital – share premium-AO conducted detailed inquiry–Revision is held to be not valid. [S. 68, 133(6)]

Cognizant Technology Solutions India (P) Ltd. v. CIT (2019) 310 CTR 350 / 181 DTR 183 (Mad.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Orders shall be passed without being influenced by any of the observation made or finding rendered by the Single Judge.

Cognizant Technology Solutions India (P) Ltd. v. CIT (2019) 310 CTR 348 / 181 DTR 181 (Mad.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision by CIT on the ground of over-valuation of shares of assessee for buy-back purposes—Directing the assessee to file necessary objections to the show-cause and such reply shall be considered by meeting out each and every objections raised, on merits and in accordance with law. [S. 92CA]

Dy. CIT v. Pacific Industries Ltd. (2019) 72 ITR 634 (Jodh.)(Trib.) Dy. CIT v. Pacific Leasing and Research Ltd. (2019) 72 ITR 634 (Jodh.)(Trib.)

S. 254(1) : Appellate Tribunal-Responded can depend the grounds, though no appeal id filed–Search and seizure–Jurisdiction issue. [S. 132, 153A, ITAT R. 27]

Dy. CIT v. Punjab Beverages (P) Ltd. (2019) 174 DTR 329 (Chd.)(Trib.)

S. 254(1) : Appellate Tribunal-Remand Assessment-Order giving effect-AO must comply the direction of the Tribunal. [S.2(8), 143(3), 250]

Dy. C. I. T. v. Roshan Lal Jindal (2019) 71 ITR 596 (Chd.)(Trib.)

S. 250 : Commissioner (Appeals)-Additional evidence-Evidence cannot be admitted without affording an opportunity to AO to cross-examine. [S. 250, R. 46A]

Genpact India Private Ltd. v. DCIT (2019)419 ITR 440/ 311 CTR 737/ 184 DTR 17 / 111 taxmann.com 402/ ( 2020) 268 Taxman 299 (SC), www. itatonline. org Editorial : Order in Genpact India Private Ltd. v. DCIT (2019) 419 ITR 370 / 181 DTR 361 / 310 CTR 505 / 108 taxann.com 340 (Delhi)(HC) is affirmed.

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders–Denial of liability–Not confined only to the liability to be assessed u/s. 143(3) of the Act-Liability to pay tax u/s. 115Q is also appealable order–Alternative remedy is available-Writ is not maintainable. [S. 15QA, 143(3), Art. 226]

Cornerview Construction & Developers (P.) Ltd. v. ACIT (2019) 56 CCH 391/180 DTR 161/178 ITD 478/202 TTJ 505 (Mum.)(Trib.)

S. 234E : Fees under section 234E-Transaction where purchase of multiple flats is made through a single letter of allotment and separate TDS statement are filed–Not to be treated as single transaction–Levy of fees is held to be valid-Appeal against levy of fees under section 234E is maintainable before CIT(A). [S. 194IA, 200(3), 246A]

ACIT v. Bansal Ship Breakers (P.) Ltd. (2019) 178 ITD 473 (Ahd.)(Trib.)

S. 206C : Collection of tax at source-Sale of scrap–Tax cannot be collected at source on those items which are capable of being used as such without any modification. [S. 206 (1)]