Year: 2019

Archive for 2019


Tristar Container Services Asia (P.) Ltd. v. ACIT (2019) 260 Taxman 277 (Mad.)(HC)

S. 37(1) : Business expenditure -Finance lease-Operating lease – Accounting Standard 19 – Matter remanded to Appellate Tribunal [S. 254(1)]

CIT(E) v. Anesthesia Society (2019) 260 Taxman 375/ 183 DTR 221 (Raj)(HC)

S. 12A : Registration –Trust or institution- Anaesthesia speciality – Education programme and research work in larger perspective were going to benefit public at large – Entitled for registration [ S.2(15) ]

PCIT v. Dilip Ranjrekar (2019) 260 Taxman 317/177 DTR 158/ 308 CTR 662 (Karn.)(HC)

S. 10(12) : Accumulated balance–Recognised provident fund – Accumulated balance lying in provident fund of assessee upto retirement is eligible for exemption.

PCIT v. H.P. Excise & Taxation Technical Service Agency (2019) 260 Taxman 302/173 DTR 13 (HP)(HC).Editorial: SLP of revenue is dismissed, PCIT v. H.P. Excise & Taxation Technical Service Agency ( 2019) 266 Taxman 280 (SC)

S. 2(24) : Income – Concept of real income- Statutory levy under the VAT Act, 2005 is being collected by virtue of the powers entrusted by the State Government to the assessee- entire collection is deposited in the Government Treasury of the State after deducting the actual expenditure incurred by the assessee- No real income accrues to the society-Not necessary to get registration u/s 12AA of the Act. [S. 4, 5, 12AA]

CIT v. Meenakshi Devi Avaru ( Smt) (Decd.) Through Legal Heirs. (2019) 410 ITR 306/ 176 DTR 1 / 308 CTR 83(Karn.)(HC) CIT v. Kamakshi Devi (Smt.) (2019) 410 ITR 306 (Karn.)(HC)

S. 2(ea) : Assets-Urban land-Belonging—Ownership-Owner-Pendency of litigation regarding ownership of land is pending for adjudication—Possession with assessee-Includible in net wealth– Protective assessment is held to be valid.

Karanjia Terminal & Logistics (P) Ltd. v. Dy. CIT (2019) 260 Taxman 320 / 306 CTR 597(Bom.)(HC)

S. 264 : Commissioner-Revision of other orders-Tax consultant was indisposed about 7 months due to serious back injury–Delay was condoned–Matter remanded back for disposal on merits. [S. 153A]

CIT v. S. R. A. Systems Ltd. (2019) 410 ITR 392 (Mad.)(HC)

S. 263 : Commissioner – Revision of orders prejudicial to revenue-Doctrine of merger—Relief granted by CIT (A)-Revision to consider eligibility of exemption is held to be not valid [ S.10A(2)(ii), 10A(2)(iii)]

CIT v. Progressive Education Society. (2019) 410 ITR 370/ 306 CTR 614 / 261 Taxman 456/ 174 DTR 281 / 262 Taxman 21(SC)/CIT (E ) v. Progressive Education Society. ( 2019) 177 DTR 58/308 CTR 198 (SC) Editorial : Order in CIT( E) v. Progressive Education Society ( 2019) 410 ITR 371/ 102 Taxmann.com 401 (Bom)(HC) is set aside.Nom No 52 of 2018 dt 9-03 -2018 is set aside .

S. 260A : Appeal-High Court–Delay of 362 days-Difference of opinion between two officers–Appeal was filed on the basis of legal opinion-Delay was condoned and remanded the matter to High Court to decide on merits- Cost of Rs. 1 lakh is awarded on department which is to be paid to the assessee.

Ambience Developers And Infrastructure Pvt. Ltd. v. CIT(2018) 171 DTR 369/ (2019) 410 ITR 289/ 307 CTR 516 (Delhi) (HC) Ambience Hotels and Resorts P. Ltd v. CIT(2018) 171 DTR 369/ (2019) 410 ITR 289 307 CTR 516 (Delhi) (HC)

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Transfer of income without transfer of asset—Finding that arrangement was with intention to avoid incidence of tax in hands of owner Assessee–Income was taxed in hands of owner— No Infirmity In Order of Tribunal. [S. 22, 60]

Prameela Krishna (Smt.) v. ITO (2019) 261 Taxman 37 (Karn.)(HC)

S. 254(1) : Appellate Tribunal–Duties–Failure of Appellate Tribunal to consider the question of jurisdiction is miscarriage of justice–Tribunal is required to reassess material and thereafter come to a logical conclusion- Order of Tribunal is set aside. [S. 147]