Author: ksalegal

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ITO v. Society for Education Conscietisation Awareness & Training (2020) 190 DTR 370 / 205 TTJ 981 (Jodhpur) (Trib.)

S. 11 : Property held for charitable purposes-Non filing of audit report online-The requirement is directory not mandatory-exemption u/s. 11 is allowed. [S. 12A, 154, Form No. 10B]

Dy.CIT v. Shri Ramdoot Prasad Sewa Samiti Trust (2020) 189 DTR 323 / 205 TTJ 435 (Jaipur)(Trib.)

S. 11 : Property held for charitable purposes-Voluntary contributions-Transaction with related party at arm’s length-Exemption cannot be denied. [S. 2(15), 12, 13(2)(g)]

Idiada Automotive Technology v. Dy.CIT (2020) 206 TTJ 114 (Delhi)(Trib.)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-No Permanent Establishment during relevant assessment year for activities relating from which Assessee had earned revenue-could not be taxed as business profit carried out through PE in India-Appeal Allowed-DTAA-India-Spain. [S. 90, Art. 13(4)]

DZ Bank AG-India Representative v. Dy.CIT (2020) 196 DTR 209 / 208 TTJ 1081 (Mum.)(Trib.)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Indian representative office and the bank itself are one unit-They are taxed only once-DTAA-India-German. [S. 2(31), 253, Art.7, 11]

Bengal Tiger Line PTE Ltd. v. Dy.CIT (2020) 196 DTR 305 / 208 TTJ 1125 (2021) 188 ITD 397 (Pune)(Trib.)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Shipping business-Invocation of article 24 of India-Singapore DTAA not justified-Exemption under article 8 is allowed-DTAA-India-Singapore. [S. 44B, 172, Art. 8, 24, Singapore Income-tax Act, S 13F]

Augustus Capital Pte Ltd. v. Dy. CIT (2020) 196 DTR 289 / 208 TTJ 1177 (Delhi)(Trib.)

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Explanation 7 to section 9(1)(i) has a retrospective effect-Sale proceeds of shares of foreign company which held investment in India is not taxable. [S. 5]

Lok Prahari Through its General Secretary S.N. Shukla IAS (Retd.) v. UOI AIR 2021 SC 2039 / 2021 SCC OnLine SC 333.

Constitution of India
Art. 224A: Appointment of retired judges at sittings of High Courts – Appointment of Ad hoc Judges – To clear backlog of cases pending in High Courts crossed 57 lakhs with ratio of vacancies of 40% – General guidelines to excise power in transparent manner .

Vijaykumar Bhima Dighe v. UOI (2022) 3 Bom CR 110/(2022) 3 MhLJ 302 ( Bom ) (HC) www.itatonline .org

Consumer Protection Act , 2019

S. 101 :Power of Central Government to make rules -Appointment of Judicial Members -Adjudicating Members – State Consumer Commission-District Consumer Forums- Tribunals-Appointment Process, Minimum experience- 20 years for appointment of President and 15 years for members of state Commission- Unconstitutional and violative of Article 14 of the Constitution of India- Advocate with 10 years of experience at the Bar eligible for appointment as Members in Tribunals- Rules-Struck down -[ Consumer Protection Rules, 2020, Rule 6 3(2)(b), 4(2)(c), 6(9), Art , 14 ]

Harshhvardhan Chhajed v. DGIT ( Raj )( HC ) www.itatonline .org

S. 132 : Search and seizure – Seizure of stock in trade – Seizure was held to be illegal – Directed to release the stock in trade and also directed to pay interest of Rs 1 lakh to the petitioner [ S. 132 (4), 132B, Art , 226 ]

Paraminder Singh Kalra v. CIT (2020) 429 ITR 577 / 196 DTR 433 / 318 CTR 211 / (2021) 279 Taxman 316 (Delhi)(HC)

S. 276D : Offences and prosecutions-Failure to produce books of accounts-Documents-Three separate complaint were part of same transaction-Clubbing of complaints and joint trail was allowed. [S. 276C(1), 277, Code of Criminal Procedure, 1973, S.200]