Author: ksalegal

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Essel Mining and Industries Ltd. v. PCIT (2022) 444 ITR 576 / 209 DTR 180/ 324 CTR 124 (Cal)(HC)

S. 4 : Charge of income-tax-Capital or revenue-Compensation received on account of failure of performance guarantee-Matter remanded to Tribunal. [S. 254(1)]

V. Vasanthakumar v. UOI (2022) 444 ITR 677 (Mad)(HC

Prohibition of Benami Property Transactions Act, 1988.

S. 32 :Qualification for appointment of chairperson and Members of Appellate Tribunal- Constitution Of Appellate Tribunal – Independence of Judiciary — Qualification of Judicial Member — Requirement that he could be a Member of Indian Legal Service or one had held post of additional Secretary or equivalent post in that service — Provision not valid. [ Art , 226 ]

Nexus Feeds Ltd v. ACIT (2022) 444 ITR 261 (Telangana) (HC),Editorial: ACIT v. Nexus Feeds Ltd (2023)453 ITR 459 (SC), Affirmed, SLP of Revenue dismissed ,

Benami Transactions (Prohibition) Amendment Act, 2016

S.2(a): Benami Property Transactions — Amendment of Act in 2016 Provisions are substantive — Not applicable with retrospective effect – Interpretation of taxing statutes —Rule against retrospectivity . [ S. 2(9)(A) (2(9)(C), Art , 20, 226 ]

PCIT v. Asish Kumar Ghosh (2022) 444 ITR 398/ 214 DTR 257/326 CTR 841 (Cal)(HC)

Direct Taxes Vivad Se Vishwas Act, 2020.

S. 2(1)(a): Appellant – Declaration processed and Form 3 issued To Assessee -Rejection of declaration -Not valid —State cannot claim benefit of its own mistake. [S. 4 , Art , 226 ]

B. D. Tea Estates Pvt. Ltd. v State of West Bengal (2022) 444 ITR 504 (Cal)(HC))

Bengal Agricultural Income-tax Act, 1944

S. 34:Method of computation -Agricultural Income -tax -Appeal dismissed – Alternative remedy – Writ is not maintainable [ West Bengal Taxation Tribunal Act, 1987, Art , 226 ]

Azad Rahim v. ITO (2022) 444 ITR 557 (Ker)(HC)

Gift-tax Act, 1958

S. 15: Assessment – Asset gifted – Valuation — Question of fact .[ S. 15(2)]

Rakesh Garg v. PCIT (2022) 443 ITR 137 / 211 DTR 265 / 325 CTR 440 (Raj.)(HC)

S. 2(1)(a) : Appellant-Declarant-Condonation of delay-Effect of Circular of CBDT dated 4-12-2020-The rejection of the declaration was not justified-The declarations of the assessee shall be accepted and thereafter dealt with as provided under the Act. [Art. 226]

Indo Arya Central Transport Ltd. v. CIT (TDS) (2022) 443 ITR 239 / 211 DTR 441 / 325 CTR 553 / 285 Taman 2 (SC) Editorial : Decision in Indo Arya Central Transport Ltd. v. CIT (TDS) (2018) 404 ITR 667 (Delhi)(HC) affirmed.

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Failure to deposit tax deducted at source-Deposited in Government Treasury after 11 months-Assessee and persons in charge to face trial-Writ petition to quash the proceedings was dismissed-Petition for Special Leave to appeal dismissed.[S. 192, Art, 136, 226].

Inland Builders Pvt. Ltd. v. Dy. CIT (2022) 443 ITR 270 (Mad.)(HC)

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Failure to file return of income-Payment of tax with interest-No wilful evasion of tax-Prosecution quashed. [S. 140A, 276C(2), 276CC]

Gyan Chand Jain v. CIT (2022) 443 ITR 241 / 213 DTR 71/ 326 CTR 241 /287 Taxman 87 (SC)

S. 271(1)(c) : Penalty-Concealment-Sanction of Joint Commissioner-Definition-Includes Additional Commissioner-Sanction of Additional Commissioner obtained-Penalty proceedings validly initiated. [S.2(28C), 260A, 271(1)(c), 274(2)].