Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


PCIT v. City Centre Mall Nashik Pvt. Ltd. (2020) 424 ITR 85 / 121 taxmann.com 87(Bom)(HC)

S.28(i):Business — Income from house property —Object of developing commercial complexes —Income earned assessable as business income [ S.22 ]

CIT(TDS) v Jeevan Telecasting Corporation Ltd (2018) 171 DTR 145 / 305 CTR 1001/ (2020)423 ITR 496 (Ker)(HC)

S.254(1) : Appellate Tribunal — Powers- Remand – Deduction at source – The Tribunal being the fact finding authority ought to look into the facts before ordering a remand on the basis of the directions issued by the Supreme Court. [ S. 194J , 201(1) 271C ]

PCIT v. Ashok Apparels (P.) Ltd (2019) 264 Taxman 50 / (2020)423 ITR 412 (Bom) (HC)

S.45: Capital gains — Transfer of bonus shares — Bonus shares in respect of shares held as stock-in-trade — No presumption that bonus shares constituted stock-in-trade — Tribunal justified in treating bonus shares as investments [ S.28(i) ]

Tenzing Match Works v. Dy CIT (2019) 182 DTR 1/ (2020) 423 ITR 312 / 314 CTR 679 (Mad)(HC)

S.32:Depreciation — Windmill —Additional depreciation – Trial run – Business of manufacture of matches- Windmill for production of electricity —Entitle to depreciation and additional depreciation .[ S.32(1)(iia) ]

Additional District Magistrate Land Acquisition. v. JCIT (TDS) (2020) 181 ITD 576 (Luck) (Trib.)

S. 271C : Penalty – Failure to deduct at source – Land Acquisition Authority – Interest payment on delayed compensation voluntarily paid to farmers -Technical breach – Levy of penalty is held to be not valid [ S.194A , Rule 29C ]

Padam Chand Pungliya. v. ACIT (2019) 71 ITR 562 / 201 TTJ 307/ (2020)181 ITD 261 / 188 DTR 258(Jaipur) (Trib.)

S. 271AAB:Peanlty -Search initiated on or after Ist day of July 2012- Disclosure of additional income in statement recorded under S. 132(4) itself is not sufficient to levy penalty unless income so disclosed falls in definition of undisclosed income defined in Explanation to S. 271AAB(1) [ S.69C , 132(4) 153 (B) (1)( b) ]

Saroj Print Arts. v. PCIT (2020) 181 ITD 502 (Mum) (Trib.)

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Best judgement assessment-Interest and remuneration paid to partners-Revision of order is held to be valid . [ S.144 , 184(5) ]

Eveready Industries India Ltd. v. PCIT (2020) 181 ITD 528 / 114 taxmann.com 610 (Kol) (Trib.)

S. 263 : Commissioner – Revision of orders prejudicial to revenue – TDS Mismatch – PCIT has issued show cause notice for seven issues and passed the revision order – Appellate Tribunal quashed the revision order after discussion all seven issues [ S .4 ,14A 37(1) 40A(2) 41(1) 43(6) 48 , 50C ,80IC ,92CA ]

Dena Bank v. PCIT (2020) 181 ITD 322 (Mum) (Trib.)

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Bad debt – Penalties – AO has called the relevant details in the course of assessment proceedings which were filed – Order of revision is held to be not valid . [ S.36(1) (vii) 37(1), 43B ]

Kartick Chandra Mondal. v. PCIT ( 2020) 181 ITD 89/192 DTR 248/ 206 TTJ 904 (Kol) (Trib)

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Investment Bonds – Month means calendar month and not period of 30 days – Period of six months is to be considered as six calendar months and not 180 Days- Entitle to exemption – Order is not erroneous [ S.54EC ]