S. 4 : Charge of income-tax -Accrual – Interest on project advance –Development agreement has not taken place as the interest has not accrued, income cannot be assessed on hypothetical basis [ S.145 ]
S. 4 : Charge of income-tax -Accrual – Interest on project advance –Development agreement has not taken place as the interest has not accrued, income cannot be assessed on hypothetical basis [ S.145 ]
S. 4 : Charge of income-tax – Capital or revenue- Notional sales tax – Question of law [ S. 260A ]
S. 4 : Charge of income-tax –Capital or revenue – Causal and non –recurring- Capital gains- Compensation paid for breach of contract was held to be capital in nature [ S. 2(24), 10(33) 45. 55(2)(a) ]
S. 4 : Charge of income-tax -Mutual concerns –Surplus earned was spent for common benefit of members of for carrying on objects of the Club – Principle of mutuality is applicable and surplus cannot be brought to tax .
S. 4 : Charge of income-tax – Interest on amount of sundry debtors outstanding cannot be charged on accrual basis [ S. 145 ]
S. 4 : Charge of income-tax – Mutuality- Receipts by Co -operative society form its members ie. Non-occupancy charges , transfer charges common amenity fund charges and other charges , are exempt from income -tax Act based on the principle of mutuality [S. 2(24), Maharashtra Co -operative Societies Act , 1960 , S. 79A ]
S.2(14)(iii) : Capital asset – Agricultural land -Capital gains- Business income- Sale of agricultural land purchased on good price and purchasing the land of higher volumes at different places cannot be regarded as trader- Entitle to exemption. [ S. 2(14) , 28(i)]
S. 2(22)(e) Deemed dividend-Beneficial owner – Prima facie, CIT v. Ankitech pvt Ltd ( 2012) 340 ITR 14 ( Delhi)( HC) and CIT v. Madhur Housing and development company ( 2018) 401 ITR 152 (SC) , is wrongly decided and should be reconsidered by larger bench.
S. 2(22)(e):Deemed dividend -loans from two companies addition cannot be made as deemed dividend [ S. 260A ]
S. 4 Income Chargeable to charge to tax-Panama Papers-PIL was Dismissed