Year: 2019

Archive for 2019


ACIT v. Navneet Kumar Sureka. (2019) 174 ITD 320 (Delhi) (Trib.)

S.68: Cash credits-Shares- Purchase of shares held to be genuine – Sale consideration cannot be assessed as assessee’s own unaccounted money [ S.45 ]

Amit Bansal v. ACIT (2019) 174 ITD 349 (Delhi) (Trib.)

S. 50C : Capital gains – Full value of consideration – Stamp – Date of agreement -Registration – Value adopted or assessed or assessable by stamp valuation authority on date of agreement is to be taken for purpose of full value of consideration- The proviso to S. 50C was inserted by the Finance Act, 2016 with effect from 1-4-2017 is prospective in nature. [ S. 2(47)(v)45 ]

Bhagini Nivedita Sahakari Bank Ltd v. DCIT (2019) 174 ITD 303 / 176 DTR 329 (Pune) (Trib.)

S. 36(1)(viia) :Bad debt-Provision for bad and doubtful debts – Schedule bank – A co-operative bank is entitled to claim deduction of bad debts provided in first part of S.36(1)(viia)(a) being 7.5 per cent of total income even in absence of rural branches.

DIT (E) v. American School of Bombay Education Trust (2019) 174 ITD 326/ 69 ITR 66/ 198 TTJ 534 (Mum) (Trib.)

S.10(22): Educational institution- Exemption cannot be denied merely on ground that it was receiving fees from foreigner students in foreign exchange abroad by way of an arrangement with an educational organisation abroad.

CIT (TDS) v. Indian Oil Corporation Ltd ( 2018) 303 CTR 188/92 taxmann.com 281 (2019) 410 ITR 106 / 166 DTR 89 (Uttarakhand) (HC)

S. 194C : Deduction at source – Contractors – Refining crude oil and selling petroleum products – Agreement with another company for transportation of goods- Works contract-Rent- Liable to deduct tax at source u/s 194C and not 194I [ S.194I ]

PCIT v. Ludhiana Central Co-Op. Bank Ltd ( 2018) 305 CTR 868/ 172 DTR 1 (2019) 410 ITR 72 (P&H)(HC)

S. 43D : Public financial institutions -Real income- Co -Operative Bank – Interest on non -performing assets -Shown in books as per RBI guidelines – Interest not accrued- Not assessable [ S.4 , 5, 145, RBI Act, 1934, S. 45Q ]

Deekay Gears v. ACIT (SMC)( 2019) 175 DTR 267/ 198 TTJ 101 /( 2020) 77 ITR 150 (Mum) (Trib) .www.itatonline.org

S. 251 : Appeal – Commissioner (Appeals) – Powers -Once appeal is filed the said appeal cannot be withdrawn by the assessee- CIT(A) has to decide the appeal on merit- Delay of 116 days in filing the appeal before the Tribunal was condoned .[ S. 246A,250(4), 253 , 254(1)

Sanspareils Greenlands (P.) Ltd. v. CIT (2019) 174 ITD 274/ 197 TTJ 55 (UO) (Delhi) (Trib.)

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Business expenditure -Advertisement and publicity-Payment to cricketer -AO allowed the expenditure after considering the explanation- Revision is not to be not justified [ S.37(1) ]

Trimurty Buildcon (P.) Ltd. v. DCIT (2019) 174 ITD 252 (Jaipur) (Trib.)

S.234E: Fee-Default in furnishing the statements- Amendment to S. 200A with effect from 1-6-2015 empowering AO levying fees under 234E is prospective- Processing TDS statements for period prior to 1-6-2015 fee cannot be charged .[ S.200A ]

ITO v. Modern Home Care Products Ltd. (2019) 174 ITD 209 / 197 TTJ 377/ 174 DTR 209(Delhi) (Trib.)

S.55: Capital gains- No cost of acquisition – Transfer of trade mark- Cost of acquisition is not ascertainable – Not liable to tax [ S.2(14),4, 45,48 , 55(2)(a)]