Year: 2019

Archive for 2019


PCIT v. Broadcom India Pvt. Ltd. (2019) 415 ITR 380 (Karn.)(HC)

S. 10A : Free trade zone–Export through third party-Entitle to deduction.

CIT v. Chandragiri Construction Co. (2019) 415 ITR 63 (Ker.) (HC)

S. 5 : Scope of total income–Accrual-Method of accounting- Amount retained under contract to ensure there are no defects in execution of contract–Amount retained did not accrue hence cannot be taxed on accrual basis. [S. 145]

Dal Chandra Rastogi v. CBDT (2019) 264 Taxman 83 (SC) Editorial: Order of High Court is reversed, Siddharth Rastogi v. CBDT (2018) 402 ITR 17/ 301 CTR 545 / 163 DTR 449 (Delhi) (HC) Dal Chandra Rastogi v. CBDT (2018) 402 ITR 17/ 301 CTR 545 / 163 DTR 449 (Delhi) (HC) Meena Rastogi v. CBDT (2018) 404 ITR 97 / 301 CTR 548 / 163 DTR 452 (Delhi) (HC)

S. 183 : Payment of tax–Failure to pay third instalment – Rejection of application was held to be not justified – Permitted assessee to deposit tax under Income Declaration Scheme belatedly subject interest @ 12%. [IDS, S. 196 IT Act, 119(2)]

PCIT v. Hotel Leela venture Ltd. (2019) 106 taxmann.com 242/ 264 Taxman 27 (Bom.)(HC)

S. 268A : Appeal–Instructions–Tax effect below Rs. 50 lakhs- Mandate issued by CBDT in circular No. 3, dated 11-7-2018- Binding on revenue-Appeal was dismissed on ground of low tax effect. [S. 260A]

Bhagavathy Velan v. DCIT (2019) 264 Taxman 146 /(2020) 187 DTR 364/ 315 CTR 119 (Mad.)(HC)

S. 268A : Appeal–Instructions-Low tax effect–Instruction No 3 dt. 9-2-2011-Neither binding on Tribunal nor Tribunal-Board cannot direct the Court or Tribunal to compel litigants to withdraw appeal due to low tax effect. [S. 254(1)]

PCIT v. Well Wisher Construction (P.) Ltd. (2019)106 taxmann.com 259 / 264 Taxman 86 (Bom.)(HC) Editorial: SLP of revenue is dismissed, PCIT v. Well Wisher Construction (P.) Ltd. (2019) 264 Taxman 85 (SC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue– Capital asset-Surrender of right, title and interest in plot allotted by MIDC in favour of third party-Not assessable as business income.[S.,2(14), 28(i), 45]

Mckinsey Knowledge Centre India (P.) Ltd. v CIT (2019) 106 taxmann.com 248 / 264 Taxman 24 (Mag.) (Delhi)(HC)

S. 260A : Appeal-Review-Transfer pricing–Arm’s length price–Following the earlier year order review petition is allowed-The appeal is restored to original file of this Court and shall be heard on its merits. [S. 92C]

PCIT v. Envision Investment & Finance (P.) Ltd. (2019) 264 Taxman 242 (Bom.)(HC)

S. 260A : Appeal-High Court–Sale of shares-Income earned from sale of shares held for more than one year–Held as long-term capital gain- Applicability Explanation to S. 73 cannot be raised for first time in proceedings pending before High Court. [S. 45, 73]

Shobha Lakshman (Smt.) v. CIT (2019) 264 Taxman 198/ 311 CTR 496 / 183 DTR 213(Karn.)(HC)/ Editorial: Shobha Lakshman (Smt) v. CIT (Appeals) (2023) 295 Taxman 237 (SC), matter is restored to the file of the CIT(A)).

S. 254(1) : Appellate Tribunal- Powers-Dismissal of appeal-Non appearance -Failure to appear on the appointed date, failure to make arrangement to represent her before Tribunal by an authorised representative and also failed to sought for another date of hearing- Dismissal of appeal by the Tribunal is held to be justified.

Amrapali Fincap Ltd. v. ITSC (2016) 73 taxmann.com 97 (Guj.) (HC) Editorial: SLP is granted to the assessee, Amrapali Fincap Ltd. v. ITSC (2019) 264 Taxman 84 (SC)

S. 245D : Settlement Commission-Application–Cross examination- Relying upon statements of witness without giving an opportunity of cross examination the application of the assessee was rejected by the Settlement Commission-High Court rejected the writ petition. [S. 245C]