Author: ksalegal

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PCIT v. Adamine Construction (P.) Ltd. (2019) 107 taxmann.com 84 / 264 Taxman 280 (Delhi) (HC) Editorial : SLP of revenue is dismissed, PCIT v. Adamine Construction (P.) Ltd. (2019) 264 Taxman 279 (SC)

S. 68 : Cash credits–Share application money-Income tax returns, balance sheet, confirmations were produced-Deletion of addition is held to be justified. [S. 131]

CIT v. Vaani Estates (P.) Ltd. (2019) 264 Taxman 310//310 CTR 12 / 180 DTR 90 / 264 Taxman 310 / (2020) 429 ITR 64 (Mad.)(HC)

S. 56 : Income from other sources–Issue of shares at premium-Fair market value of shares-AO has to undertake exercise of determining fair market value of shares-Matter remanded. [S. 56 (2)(viib), 119]

PCIT v. Vernan (P.) Trust (2019) 107 taxmann.com 432 / 265 Taxman 158 (Bom.)(HC) Editorial : SLP of revenue is dismissed, PCIT v. Vernan (P.) Trust. (2019) 265 Taxman 157 (SC)

S. 45 : Capital gains–Business income-Sale of shares-Shares settled by settlor – Shares received by way of Employee Stock Option Plan-Assessable as capital gains and not as business income-Entitle to exemption. [S. 10(38), 28(i)]

PCIT v. NEO Sports Broadcast (P.) Ltd. (2019) 264 Taxman 323 (Bom.)(HC)

S. 40A(2) : Expenses or payments not deductible–Excessive or unreasonable-TV broadcasting right of cricket match-Cancellation of one match and addition of another match-Addition of price difference in broadcasting rights of matches cannot be made.

PCIT v. Cricket Club of India. (2019) 265 Taxman 95 (Bom.)(HC)

S. 37(1) : Business expenditure–Capital or revenue-Fixing of MS sliding gates, different pipes for sprinkler system in main ground, excavation of soil, purchasing of LED replay screen, electric materials etc., for upgrading stadium in accordance with ICC Standards, is revenue in nature.

Indian Railway Stations Development Corporation Ltd. v. PCIT (2019) 265 Taxman 11 (Mag.)/ 178 DTR 425 /(2020) 314 CTR 271 (Delhi)(HC)

S. 37(1) : Business expenditure–Commencement of business– Service sector–Preliminary steps, such as engaging in negotiation or employment of personnel, could be regarded as an activity of commencement of business–Expenditure is held to be allowable.

Mahindra World City Developers Ltd. v. ACIT (2019) 417 ITR 241/ 264 Taxman 328/180 DTR 299 (Mad.)(HC)

S. 36(1)(iii) : Interest on borrowed capital-Acquisition of capital asset-Business of land development for industrial, commercial and residential use-Proviso to section 36(1)(iii) override provision of section 145A–Disallowance of claim of interest is held to be justified. [S. 145A]

CIT v. Rajapalayam Mills Ltd. (2019) 265 Taxman 209 (Mad.)(HC)

S. 35 : Scientific research-Expenditure on scientific research is held to be allowable as deduction-Order of Tribunal is affirmed. [S. 35(2AB)]

CIT v. Plaza Hotels (P.) Ltd. (2019) 107 taxmann.com 287 / 265 Taxman 90 (Bom.)(HC) Editorial : SLP of revenue is dismissed, CIT v. Plaza Hotels (P.) Ltd. (2019) 265 Taxman 89 (SC)

S. 28(i) : Business income–Leasing the hotel and charging one percentage of total revenue–Assessable as business income and not as income from house property.[S. 22, 23]

CIT v. Khatu Ji Para Medical Technology Educational & Research Society. (2019) 264 Taxman 300 (P& H) (HC)

S. 12AA : Procedure for registration–Trust or institution-Running of college and educational institutions-Denial of registration is held of be not valid. [S. 10(23C)(vi)]