Author: ksalegal

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CIT v. Karnataka State Cricket Association. (2019) 416 ITR 604 (Karn.)(HC)

S. 11 : Property held for charitable purposes–Amount spent on acquisition of capital assets is allowed as application of income for charitable purposes – Depreciation is allowable.[S. 11(2), 32]

CIT v. Keventer Agro Ltd. (2019) 416 ITR 482 (Cal.) (HC)

S. 4 : Charge of income-tax–Subsidy from State Government– Capital receipt. [S. 2(24)]

PCIT v. Ankit Metal and Power Ltd. (2019) 416 ITR 591 / 182 DTR 333/ 266 Taxman 237/ 311 CTR 369(Cal.)(HC)

S. 4 : Charge of income-tax–Subsidies–Receipts of interest and power subsidiaries-Capital receipts-Amendment is prospective- Receipts not being nature of income cannot be included for purpose of computing book profit. [S. 2(24), 115JB]

CIT v. Malayil Bankers. (2019) 416 ITR 322/( 2020) 185 DTR 347 / 314 CTR 568(Ker.)(HC)

S. 2(31)(v) : Person-Association of persons-No partnership deed -No unity of control-Assessment as Association of persons is justified. [S. 132]

Sharda Pareek (Smt.) v. ACIT (2019) 416 ITR 441 /104 taxmmann.com 76/262 Taxman 253(Raj) (HC) Editorial : SLP is granted to the assessee Sharda Pareek (Smt.) v. ACIT (2019) 412 ITR 31 (St)// 262 Taxman 252 (SC)

S. 2(28A) : Interest-Accrual basis-Interest on compensation awarded by Motor Accident Claims Tribunal is taxable on year wise accrual basis. [Motor Accident Claims Tribunal]

CIT v. Kalathingal Faizal Rahman. (2019) 416 ITR 311 (Ker.) (HC)

S. 2(14)(iii) : Capital asset-Agricultural land-Burden is on assessee to prove that the land was agricultural-Mere certificate by village Officer after sale of land is not sufficient–Gains assessable as capital gains. [S. 45]

Sanjay Dattatray Kakade v. A CIT (2019) 70 ITR 519 (Pune)(Trib.)

S. 271AAA : Penalty-Search initiated on or after 1st June, 2007– Retraction of statement–Filing the return admitting the additional income after retraction the assessee is not entitle to exemption-No requirement of recording satisfaction before imposing penalty-Immunity from penalty–Conditions to be satisfied cumulatively i.e. surrender undisclosed income and to specify manner in which such income derived ,and pay taxes with interest in respect of undisclosed income along with return. CIT(A) has the power to enhance the penalty.[S. 132(4), 251, 271AAA(2)]

DCIT v. Rajendra Agarwal (2019) 71 ITR 518 (Jaipur)(Tirb.)

S. 271(1)(c) : Penalty–Concealment-Long term capital gains-Surrender and disclosure u/s. 132(4)-In absence of any incriminating material found during search and seizure action would not lead to conclusion that assessee has concealed particulars of income or furnishing inaccurate particulars of income. [S. 10(38), 45, 132(4), 153A]

ACIT v. St. Antony Timber Depot and vice versa (2019) 71 ITR 1 (Cochin)(Trib.)

S. 271(1)(c) : Penalty–Concealment–CIT(A) confirmed the penalty only in respect of 1/3rd addition-Matter remanded to CIT(A). [S. 153A]

Simran K. Sayyed (Ms.) v. ITO(2019) 70 ITR 472 (Bang.)(Trib.)

S. 271(1)(c) : Penalty–Concealment–Additional ground-Failure by Assessing officer to delete inappropriate words and parts in relevant paragraph of notice-Notice not specifying issued for concealment of income or furnishing of inaccurate particulars of income-Levy of penalty is not valid. [S. 274]