Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


CIT, LTU v . Bosch Limited (2020) 425 ITR 667 (Karn)(HC)

S. 260A : Appeal – High Court – Monetary limits –In view of the Circular issued by the Central Board of Direct Taxes, the present appeal is dismissed as withdrawn/not pressed without answering the purported substantial questions of law.

CIT v. Sutherland Global Services Pvt. Ltd. (2020) 426 ITR 499 (Mad) (HC)

S. 260A : Appeal – High Court -Capital or revenue – Income from other sources — Reimbursement received on account of assets purchased -— Department not appealing against orders for other years on same facts — Appeal not maintainable .[ S.4 ]

Braganza Construction Pvt. Ltd. v. ACIT (2020)425 ITR 115 / 193 DTR 332 (Panaji ) (Bom)(HC )

S.254(1): Appellate Tribunal – Duties – Additional evidence —Failure by Appellate Tribunal to exercise jurisdiction vested in it — Matter Remanded to Appellate Tribunal [ S.69C 260A ATR, 1963 , R.29 ]

Ramco Industries Ltd. v. Dy. CIT (2020) 426 ITR 388 / 273 Taxman 364/ (2021) 201 DTR 84 / 320 CTR 616(Mad)(HC)

S. 254(1) : Appellate Tribunal – Duties- Natural Justice —Additional evidence — Opposing party should be given opportunity to rebut evidence — Tribunal cannot reliance upon a google study in order to have an idea about the air pollution control equipment without giving an opportunity to rebut the evidence – Order of Appellate Tribunal set aside [ S. 131(1) , 255(6) ]

CIT v .D. M. Purnesh (2020) 426 ITR 169 (Karn)(HC)

S. 250 : Appeal – Commissioner (Appeals) – Powers- Remand – order passed on the basis of remand report in which the Assessing Officer has accepted the contention of the assessee – Order of Appellate Tribunal is affirmed . [ S .250(4) ]

PCIT v. Shankarlal Nebhumal Uttamchandani (2020) 425 ITR 235 /186 DTR 169/ 114 taxmann.com 638/ 270 Taxman 41/313 CTR 184 (Guj) (HC), Editorial: SLP filed by the revenue ,notice issued , returnable on 12 -3 2021, in the meanwhile , the effect and operation of the order presently underchallenge shall remain stayed , PCIT v. Shankarlal Nebhumal Uttamchan ( 2021) 279 Taxman 326 ( SC)

S. 245D : Settlement Commission -Full and true disclosure-Income offered in application-Additional income offered during proceedings in order to avoid controversy – No new source of income —Acceptance of offer and passing of order by Settlement Commission is held to be justified .[ S. 133A, 245C , 245D(4) , ITSC (P)Rules, 1997. R.9 , Art , 226 ]

CIT v. ITSC (2020) 425 ITR 568 / 192 DTR 217/ 273 Taxman 264(Mad)(HC)

S. 245D : Settlement Commission – Amendment in law — Payment of additional tax on additional amount disclosed within time prescribed — Settlement Commission has jurisdiction to proceed with application – Failure to consider report filed by department — Matter remanded to Settlement Commission for disposal afresh. [ S.245C(1),245D(2A), 245D(4) ITSC (Procedure) Rules, 1997, R. 9, Art .226 ]

Mulberry Silks Ltd v .ITST (2020) 426 ITR 444 / 117 Taxman 62/ 274 Taxmann 320/ (2021) 201 DTR 56 (Mad) (HC)

S. 245C : Settlement Commission – Settlement of cases –Territorial Jurisdiction of Madras High Court — Order of Bench of Settlement Commission at Chennai — Petition not maintainable -Place where cause of action arises – Doctrine of Forum Conveniens .[ S. 132, 226 ]

Huawei Telecommunications (India) Company Pvt Ltd v .UOI (2020)426 ITR 572 / 195 DTR 233 / 317 CTR 571 (P&H)(HC)

S.241A: Refund- Withholding of refund in certain cases – Mere pendency of the proceedings under S. 143(2) in itself is not enough to withhold the refund .[ S. 143(1) ,143 (2), Art .226 ]

Vodafone Idea Ltd v. ACIT (2020)425 ITR 691/ 272 Taxman 335 (Bom)(HC) Editorial : SLP of revenue is dismissed , PCIT v. Vodafone Idea Ltd (2020) 272 Taxman 406 ( SC)

S. 237 : Refund -Order of refund attaining finality- Department cannot adjust admitted refund against future dues yet to be adjudicated —Entitle to refund- Department Withholding refund of Assessment Year 2014-15 — Provisions not attracted to refund of assessment Year 2014-15 or any Assessment year prior to Assessment Year 2017-18. [ S.143(1) 144C ,154, 241A , 245 Art , 226 ]