Author: ksalegal

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Arjun Malhotra v. CIT (2018) 403 ITR 354/166 DTR 235/ 255 Taxman 399/ 304 CTR 454 (Delhi) (HC)

S. 48 : Capital gains – Computation -Difference between market value and consideration declared, burden is on the revenue to prove -Addition was deleted [S. 45,52(1) ]

Arjun Malhotra v. CIT (2018) 403 ITR 354/166 DTR 235/ 255 Taxman 399/ 304 CTR 454 (Delhi) (HC)

S.45:Capital gains — Shares purchased was pledged with bank – Actual date of transfer is when shares were delivered by bank to entity in subsequent assessment year. [ S.48 ]

CIT v. Allen Career Institute. (2018) 403 ITR 375 / 161 DTR 321 (Raj) (HC)

S. 40(b)(v) : Amounts not deductible – Partner – Remuneration – Interest earned on investment of surplus money is not part of business income for computing the remuneration to partners – Disallowance was held to be justified .[ S.56 ]

CIT v. Shri Balaji Samaj Vikas Samiti. (2018) 403 ITR 398/164 DTR 56 (All) (HC)

S. 12AA : Procedure for registration –Trust or institution- Providing mid-day meals at Village Schools is charitable purpose which is entitle to registration . [ S.2(15) ]

CIT v. Haryana State Pollution Control Board. (2018) 403 ITR 337 (P&H) (HC)

S. 10 (23C): Exemption- Approval granted is held to be valid till it is withdrawn -Amount spent on the object was held to be allowable .[ S. 10(23C)(iv) ]

Yogesh Roshanlal Gupta v CBDT (2018) 403 ITR 12 (Guj) (HC)

Income Declaration Scheme, 2016 -Finance Act, 2016 ( 2016) 384 ITR 1 (St) (IDS)

S.187: Time for payment of tax -Power to extend the payment of tax – CBDT has the power to condone the delay in depositing the tax .Matter remanded to CBDT to consider the request of the assessee. [ S.119, 183, 184 ]

PCWT v. Padma Dalmia. (2018) 403 ITR 150 / 165 DTR 57 / 303 CTR 125(Delhi) (HC) PCWT v. Raghu Hari Dalmia. (2018) 403 ITR 150 / 165 DTR 57/ 303 CTR 125(Delhi) (HC)

Wealth tax -Act , 1957

S.7: Net wealth- Value of assets- Valuation of all assets and the valuation operated not on a year-to-year basis but for a four year cycle. The only exception was that where jewellery included gold or silver or any other alloy, the valuation of gold had to be undertaken annually- Deletion of addition was held to be justified .[ Wealth-tax Rules, 1957, 18 , 19 ]

CIT v. Ritu Singal (Smt) (2018) 403 ITR 97 / 164 DTR 153/ 303 CTR 738(Delhi) (HC)

S. 271AAA : Penalty – Search initiated on or after 1st June, 2007 –Manner in which undisclosed income earned was not satisfied -Deletion of penalty was held to be not valid [S. 132(4) ]

Academy Of Medical Sciences v. CIT (2018) 403 ITR 74/ 254 Taxman 419 / 170 DTR 388/ 305 CTR 659 (Ker) (HC)

S.260A:Appeal -High Court- Procedure for registration –Trust or institution-In appeal High Court cannot direct the Commissioner to grant the registration for earlier years .[ S.12AA ]

Crompton Greaves Limited v. CIT ( 2018) 64 ITR 43 (SN)(Mum)(Trib) , www.itatonline.org Editorial: Crompton Creaves Ltd v. CIT ( 2016) 46 ITR 465/ 177 TTJ 1/(2017) 82 taxmann.com ( Mum) (Trib) is recalled.(S.263. Revision –Explanation 2 is declaratory nature.) Tribunal in Crompton Creaves Ltd v. CIT vide order ITA No 1994/Mum/ 2013 dt 28-02 2019 ( AY. 2007 -08) held that revision is held to be invalid .

S. 254(2):Appellate Tribunal-Rectification of mistake apparent from the record-Excessive delay by the Tribunal in passing judgement shakes the confidence of the litigants. orders have to be passed invariably within three months of the completion of hearing of the case. The delay is incurable. Even administrative clearance cannot cure the delay. Such decisions rendered after 3 months reflect a mistake apparent from the record and have to be recalled and the appeals heard afresh .[ R.34(5)]