Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Estate of Late Dr. S. Zakaulla Masood. v. ITO (2021) 186 ITD 326 / 199 DTR 243 / 210 TTJ 779 (Bang.)(Trib.)

S. 54 : Capital gains-Profit on sale of property used for residence-Construction of house within period of three years from the transfer of original asset-Non availability of occupation certificate cannot be the ground to deny the exemption. [S. 45]

Jayshree Shankar Done (Smt.) v. ITO (2021) 186 ITD 257 (Pune) (Trib.)

S. 45 : Capital gains-Transfer-Sale agreement registered on 26-8-2011 and possession was also handed over on the said date-Capital gains assessable in assessment year 2012-13. [S. 2(47), 54F]

Sri Balaji Prasanna Travels. v. ACIT (2021) 186 ITD 534 / 199 DTR 209 / 210 TTJ 970 (Bang.)(Trib.)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Transportation charges-Hiring cabs from cab owners-Liable to deduct tax at source-Payment made to petrol pumps not liable to deduct tax at source. [S. 194C]

Digi Drives (P.) Ltd. v. ACIT (2021) 186 ITD 459 (Delhi)(Trib.)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission payment-Mere rendering of service of procurement of export orders by a non-resident company for Indian company does not fall in category of managerial/consultancy services-Not liable to deduct tax at source-DTAA-India-Japan. [S. 40(a)(1), 195]

DCIT v. Edelweiss Commodities Services Ltd. (2021) 186 ITD 189 / 198 DTR 234 / 210 TTJ 914 (Mum.)(Trib.)

S. 28(i) : Business loss-Trading activities in stock and commodities-Provision for loss mark to market loss on trading in derivative-Allowable as business loss. [S. 37(1)]

DCIT v. Edelweiss Commodities Services Ltd. (2021) 186 ITD 189 / 198 DTR 234 / 210 TTJ 914 (Mum.)(Trib.)

S.14A : Disallowance of expenditure-Exempt income-Net interest could be disallowed-Book Profit-Computation under clause (f) of Explanation 1 to section 115JB(2) is to be made without resorting to computation as contemplated under section 14A read with rule 8D. [S. 115JB, R. 8D]

Tata Power Co. Ltd. v. PCIT (2021) 186 ITD 82 (Mum.)(Trib.)

S.14A : Disallowance of expenditure-Exempt income-Interest free funds is more than investments made-No disallowance of interest can be made-Administrative expenses-Disallowance is restricted only to investments giving rise to exempt income. [R. 8D]

DCIT v. Shri Vaishnav Polytechnic College Govn by VSK Market Tech Educational Society. (2021) 186 ITD 378 (Indore)(Trib.)

S. 11 : Property held for charitable purposes-Exemption denied and income assessed as income from other sources-All incidental expenditures laid out by assessee wholly or exclusively for purpose of making or earning such income were also to be allowed under section 57(iii). [S. 10(23C)(iiiab), 12A, 12AA, 57(iii)]

Dy. CIT v. Wayne Burt Petrochemical (P.) Ltd. (2021) 186 ITD 186 (Chennai)(Trib.)

S. 10B : Export oriented undertakings-Matter remanded by the Tribunal to the Assessing Officer examine the claim under section 10A of the Act-CIT (A) allowed the claim under section 10B-CIT (A) was not justified is allowing the deduction u/s. 10A of the Act. [S.10A, 254 (1)]

Seth Ramjidas Modi Vidhya Niketan Society. v. CIT (2021) 186 ITD 119 / 197 DTR 33 / 209 TTJ 118 (Jaipur)(Trib.)

S. 10 (23C): Educational institution-Demerger-Financial help to hospital-No violation of provision-Withdrawal of exemption is not justified. [S. 10(23)(vi)]