Year: 2019

Archive for 2019


CIT v. Stovec Industries Ltd. (2019) 416 ITR 63 (Guj) (HC)

S. 45 : Capital gains —Sale of land and building — Sale of land taxable as long term capital gains and sale of building as short term capital gains [ S.2(29A),2(29B), 50 ]

CIT v. Stovec Industries Ltd. (2019) 416 ITR 63 (Guj) (HC)

S. 37(1) : Business expenditure – Accrued or Contingent liability- Provision for warranty on scientific basis – Held to be allowable .

CIT v. Jubiliant Enterprises P. Ltd. (2019) 416 ITR 58 (Bom) (HC) Editorial: SLP is granted to the revenue , CIT v. Jubiliant Enterprises P. Ltd. ( 2017) 397 ITR 32 (St)

S.23: Income from house property- Annual value – Interest free deposit – Rented property – Deletion of the 12 per cent. interest on the interest-free deposit received by the assessee, to determine the annual letting value of the rented property- Held to be valid . [ S.22, 24 ]

CIT v. Jubiliant Enterprises P. Ltd. (2019) 416 ITR 58 (Bom) (HC) Editorial: SLP is granted to the revenue , CIT v. Jubiliant Enterprises P. Ltd. ( 2017) 397 ITR 32 (St)

S. 14A : Disallowance of expenditure – Exempt income -Interest – Disallowance can be only on net interest on the loan . [ R.8D ]

CIT v. Gujarat State Fertilizers and Chemicals Ltd. (2019) 416 ITR 13 (Guj) (HC)

S. 14A : Disallowance of expenditure – Exempt income – Recording satisfaction – Mixed funds -Recording of satisfaction is mandatory- Disallowance is not attracted automatically . [ R.8D ]

Regen Powertech P. Ltd. v. DCIT ( 2019) 416 ITR 95 (Mad) (HC)

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Payment for installation of wind turbine, repairs to wind Turbine and for market study — Services rendered technical in nature -Liable to deduction of tax at source- DTAA -India – Sri Lanka . [ S.195 , 260A, Art, (12)(2) . ]

DCIT v. Shri Dawood Abdulhussain Gandhi ( Mum) (Trib)

S. 54F: Capital gains – Investment in a residential house – Part ownership in property – Not considered absolute ownership – Assesse eligible on the date of transfer of original asset – Exemption is allowed . [ S.45 ]

Ballabgarh Co-Operative Milk Producers Union Ltd. v. ACIT (2019)73 ITR 434 (Delhi)(Trib.)

S.271(1)(c) – Penalty – Concealment – In order to levy penalty, it should be proved that assessee has consciously concealed income or furnished inaccurate particulars and penalty proceedings were vitiated if AO did not mention the limb under which penalty is levied under section 271(1)(c) in the notice [ S.274 ]

BSM Developers Pvt.Ltd v. ITO(2019)179 DTR 193 / 73 ITR 69 / 200 TTJ 388 (Delhi) (Trib)

S. 271(1)(c) : Penalty –Concealment – Notice u/s 274 issued without striking off the irrelevant words show non-application of mind by the AO. [ S.274 ]

Allahabad Bank Karamchari Co-Operative Credit Society Ltd. v. ITO(2019)73 ITR 700 / 180 DTR 449/ 179 ITD 108 (Luck.)(Trib.)

S. 148: Reassessment- Notice- Order on appeal – If notice u/s 148 is beyond the time limit, the CIT(Appeals) cannot give direction u/s 150 to the AO to execute remedial action u/s 148 [ S. 147, .148 149(1) (b), 150 ]