Year: 2020

Archive for 2020


Arihant Constructions v. ACIT (2020)77 ITR 171 (Vishakha)(Trib.)

S. 43B : Deductions on actual payment-Employees’ contribution to provident fund and employees’ state insurance fund-Payment was made before due date of filing of return–Entitle to deduction. [S. 139(1)]

Debjyoti Dutta v. ITO (2020)77 ITR 17(SN) (Cuttack)(Trib.)

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits–Cash paid for labour charges and purchases-Business in a remote area-Disallowance is held to be not valid-Machine hire charges–less than Rs. 20000 per day–AO is directed to verify and decide. [S. 40(a)(ia)]

Mayasheel Construction v. Dy.CIT (2020) 77 ITR 8 (SN) (Delhi) (Trib.)

S. 40(b)(iii) : Amounts not deductible-Working partner– Remuneration–Interest-Rejection of books of account and assessment adopting 8 Per cent. of gross turnover as net profit-Separate deduction towards interest on partner’s capital account and remuneration to partner is to be allowed, when net profit is estimated from gross receipts. [S. 133A]

Aquarelle India P. Ltd. v. Dy. CIT (2020)77 ITR 2 (SN) (Bang.)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source–Service rendered by foreign agent–Contradictory finding–New workmen-Should be regular workmen employed in financial year relevant to assessment year–Matter remanded to the AO. [S. 80JJA, 195,254(1)]

ITO v. Ascendum KPS P. Ltd. (2020) 77 ITR 12 (SN) (Ahd.)(Trib.)

S. 37(1) : Business expenditure-Consultancy fee-Failure to submit original bills cannot be a ground for making disallowance– Disallowances cannot be made on ad-hoc basis. [S. 145]

Panarc Consulting Group Pvt. Ltd. v. ITO (2020) 77 ITR 50 (SMC) (SN) (Delhi)(Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Share application money is capital borrowed for purpose of business or profession until shares are allotted-Allowable as deduction. Consulting charges-Matter remanded to AO. [S. 37(1)]

ACIT v. Transenergy Ltd. (2020) 77 ITR 74 (SN)(Chennai)(Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Advances for construction of factory building-No disallowance can be made-Reimbursement of expenses–Matter remanded. [S. 40(a)(ia)]

ATS Infrastructure Ltd. v. ACIT (2020) 77 ITR 70 (SN) (Delhi)(Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Interest free loans and advances to related party-Free funds available-Presumption that investments from interest-free funds available-No disallowances can be made.

Arihant Constructions v. ACIT (2020) 77 ITR 171 (SN) (Vishakha)(Trib.)

S. 32 : Depreciation-Not in business of running vehicles on hire-Not entitled to depreciation at higher rate.

L & T Housing Finance Ltd. v. Dy.CIT (2020) 77 ITR 85 (SN) / 186 DTR 153/203 TTJ 835 (Chennai)(Trib.)

S. 28(i) : Business loss-Housing Finance-Pre-termination of loan– Onus on AO to show that loss claimed by assessee was tax evasion device-Matter remanded. [S. 254(1)]