Year: 2019

Archive for 2019


CIT v. Sidhi Vinayak Metcon Ltd. (2019) 414 ITR 402 (Jharkhand) (HC)

S. 68 : Cash credits—Share application money—Received by cheques- Details furnished–Burden is discharged-Failure by department to investigate identity of shareholders and genuineness of transactions—Addition is held to be not justified.

CIT v. Hazarilal Goyal (Deceased) (2019) 414 ITR 565 (Raj)(HC) Editorial: SLP of revenue is dismissed CIT v. Hazarilal Goyal (Deceased)( 2018) 406 ITR 32 (St)

S. 45 : Capital gains–Business income-Sale of land assessable as capital gains. [S. 4, 28(i)]

PCIT v. Haryana State Industrial and Infrastructure Development Corporation Ltd. (2019) 414 ITR 632/ 183 DTR 244 / 311 CTR 603/108 taxmann.com 540/ 266 Taxman 9 (Mag) (P&H) (HC)

S. 45 : Capital gains–Business income-Profit on sale of investment is assessable as capital gains. [S. 10(38), 28(i)]

CIT v. Harrisons Malayalam Ltd. (2019) 414 ITR 344/ 183 DTR 302 / 266 Taxman 414/ 311 CTR 802(Ker.)(HC)

S. 45 : Capital loss-Loss on sale of shade tree–Capital loss allowed to be carried forward.

ACIT v. Salauddin. (2019) 414 ITR 335 (Pat.)(HC)

S. 40(a)(ia) : Amounts not deductible-Deduction at source- Rejection of Books of account-Estimation of profit @ 8% of turnover—No disallowance can be made u/s. 40 of the Act. [S. 145(3)]

CIT v. Harrisons Malayalam Ltd. (2019) 414 ITR 344 / 183 DTR 302/ 266 Taxman 414/ 311 CTR 802(Ker.)(HC)

S. 36(1)(iii) : Interest on borrowed capital-Loan to sister concern from non –interest bearing funds–No disallowance can be made.

CIT v. DSP Adiko Holdings Pvt. Ltd. (2019) 414 ITR 555 (Bom.) (HC) CIT v. DSP HMK Holdings P. Ltd (2019) 414 ITR 555 (Bom.)(HC)

S. 14A : Disallowance of expenditure-Exempt income–Satisfaction-AO cannot disallow the expenditure far in excess of what has been disallowed, without demonstrating how the working of the assessee is wrong. [R. 8D]

Indian Medical Trust v. CIT (2019) 414 ITR 296/ 265 Taxman 473/ 311 CTR 19/182 DTR 252 (Raj.)(HC)

S. 12AA : Procedure for registration–Trust or institution-Cancellation of registration cannot be done retrospective effect- Education- Amounts spent on construction of buildings and acquisition of Television channel for educational purposes-Entitle to exemption-Depreciation is allowable–Proviso inserted w.e.f. 1-4 .2015 is not retrospective–High Court has the power to set aside the order of Settlement Commission which i.e. erroneous. [S. 11, 12AA(3), 245D(4), Art. 226.]

CIT(E) v. Mahima Shiksha Samiti (2019) 414 ITR 673 (Raj.)(HC)

S. 11 : Property held for charitable purposes–Depreciation is allowable–Amount transferred to private university–Exemption cannot be denied–Expenditure on foreign travel for purpose of Trust- Held to be allowable. [S. 12AA, 13, 32]

CIT v. Bechtel International Inc. (2019) 414 ITR 558 / ( 2020) 113 taxmmann.com 514 / 192 DTR 422(Bom.)(HC)

S. 5 : Scope of total income-Accrual-Real income theory-Bad debt -Mercantile system of accounting-Bill raised for premature termination of contract-Contracting company not accepting Bill- Income did not accrue–Another bill of which a small part is received after four years–Claim as bad debt is to be accepted. [S. 36(1)(vii)]