Year: 2019

Archive for 2019


Deepak Rugs. v. CIT (2019) 418 ITR 179/ 310 CTR 135 / 180 DTR 141 / 267 Taxman 262 (All.) (HC)

S. 145 : Method of accounting–Not maintaining of stock record-Rejection of books of account is held to be valid-CIT(A) has the power of enhancement after giving an opportunity of hearing-No substantial question of law.[S. 145(3), 251]

Cama Hotels Ltd. v. Samir Vakil for his successor Dy. CIT (OSD) (2019) 418 ITR 109 / 182 DTR 129/ 311 CTR 537(Guj.)(HC)

S. 142(2A) : Inquiry before assessment–Special audit–Complexity in accounts–Order to Special audit is held to be valid-Juristic person like a company cannot file a writ petition. [Art. 226]

PCIT v. Sahara States, Gorakhpur. (2019) 418 ITR 168 / 310 CTR 457/181 DTR 265 / 267 Taxman 130 (All.)(HC)

S. 80IB(10) : Housing projects- Condition that completion certificate must be obtained within four years from local authority -Amendment is not retrospective —Not applicable prior to 1-4-2005 – Order of Tribunal quashing the reassessment is held to be valid. [S. 147, 148]

Swastik Realtors v. ACIT (2019) 418 ITR 1/ 267 Taxman 27 / 311 CTR 946/ ( 2020) 186 DTR 186(Bom.) (HC)

S. 68 : Cash credits–Loan–Accommodation entries-Creditor admitting loan was not genuine–Retraction of admission after more than two years–No evidence was produced to prove genuineness of loan-Order of Tribunal is affirmed-No substantial question of law. [S. 131, 133A, 260A]

PCIT v. Vijay S. Poojari (2019) 109 taxmann.com 212 / 266 Taxman 183 (Bom) (HC) Editorial : SLP of the revenue is dismissed; PCIT v. Vijay S. Poojari. (2019) 266 Taxman 182 (SC)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Contractors-Turnover did not exceed monetary limit prescribed under the Act for tax audit – Not liable to deduct tax at source-Disallowance cannot be made for failure to deduct tax at source. [S. 44AB, 194C]

PCIT v. BMC Software India (P.) Ltd. (2019) 109 taxmann.com 277 / 266 Taxman 179 (Bom.)(HC) Editorial : SLP of revenue is dismissed, PCIT v. BMC Software India (P.) Ltd. (2019) 266 Taxman 178 (SC)

S. 10A : Free trade zone-Disallowance of expenses-Enhanced profit due to statutory disallowances–Entitle to deduction. [S.40(a)(ia)]

National Stock Exchange Investor Protection Fund Trust. (2019) 109 taxmann.com 275 / 266 Taxman 181 (Bom.)(HC) Editorial : SLP of revenue is dismissed; National Stock Exchange Investor Protection Fund Trust. (2019) 266 Taxman 180 (SC)/ 416 ITR 129 (St.)(SC)

S. 10(23EA) : Investor Protection Fund–Trust which is qualified under Sections 11 to 13 could also claim exemption–Rejection of claim is held to be not justified. [S. 11, 12, 13]

Dhanalakshmi Bank Ltd. v. CIT (2019) 410 ITR 280/ 261 Taxman 521 / 177 DTR 48/ 308 CTR 484 (Ker) (HC) Editorial: SLP of the assessee is dismissed , Dhanalakshmi Bank Ltd. v. CIT ( 2019) 266 Taxman 185 (SC)

S. 43B : Deductions on actual payment – Provision for leave encashment- Not allowable as deduction .[ S.43B(f) ]

Agson Global Pvt. Ltd. v. ACIT ( 2019) 76 ITR 504 (Delhi)(Trib),www.itatonline.org

S. 69C : Unexplained expenditure – Bogus purchases – AO cannot blow hot & cold by disallowing the purchases from a party as bogus while treating sales to same party as genuine-Entire purchases cannot be disallowed – Percentage of addition to gross profit is held to be justified.

Agson Global Pvt. Ltd. v. ACIT (2019) 76 ITR 504 (Delhi)(Trib),www.itatonline.org

S. 68 : Cash credits – Share capital – Share premium- Additional grounds -Photocopies of blank share transfer forms, blank signed receipts etc necessary for transfer of shares found with assessee are not admissible as evidence u/s 61 of Evidence Act and not incriminating in nature- All investors are assessed & have filed confirmations with trail of funds- AO did not make further inquiry into the documentary evidences or verify the trail of source of funds-Addition is held to be not justified . [ S.132(4) ,145A, 153A Evidence Act ,S.61 ].