Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Dy. CIT v .Villoo Zareer Morawala Patel (Smt.) (2020) 78 ITR 17 (SN) (Bang) (Trib))

S. 15 : Salaries – Director- Assessable on accrual basis and not on receipt basis — Salary shown in form 26 AS filed by company alone to be taxed — Assessing Officer is directed to examine factual aspect [Companies Act, 1956, Schedule XIII ]

ACIT v. Amartara P. Ltd. (2020) 78 ITR 46 (SN) (Mum) (Trib)

S. 14A : Disallowance of expenditure – Exempt income -— Investments not generating any income — Disallowance of interest on borrowed funds uilised for making investments cannot be made .[ R.8D ]

Sanjhi Sikhiya Foundation v. CIT(E) (2020) 78 ITR 31(SN) ( Amritsar) (Trib)

S. 12AA : Procedure for registration –Trust or institution- Education — Yoga – Entitle to registration [ S.2(15) 11 ]

Sneha Trust for Charity and Education v. ACIT (2020) 78 ITR 25 (SMC) (SN)( Cochin) (Trib)

S. 11 : Property held for charitable purposes – Donations – If disclosure of income in hands of assessee as corpus fund and income applied for charitable purposes and assessee has due registration- Addition cannot be made as cash credits . [ S.12A, 68 ]

National Stock Exchange Investor Protection Fund Trust v. Dy. CIT (E) (2020) 78 ITR 12 (SN) (Mum) (Trib)

S. 11 : Property held for charitable purposes – Accumulation of income – Details of purposes for which income accumulated need not be specified in Form 10- Investor protection fund Trust — No prohibition in law that trust qualified under Sections 11 to 13 could not claim exemption. [ S.11(2) ,13(3), Form No. 10 ]

Paul Xavier Antonysamy v. ITO (2020) 183 ITD /453/ 78 ITR 48 (SN) (Chennai) (Trib)

S. 6(1) : Residence in India – Individual -Period of stay in India -Staying in India for 151 days – Salary received for period in respect of services rendered abroad – Not taxable in India- DTAA -India – Australia- [ S.15 , Art .15 ]

Trans Freight Containers Ltd. v. Dy. CIT (2020) 78 ITR 5 (SN) (Mum) (Trib)

S. 4 : Charge of income-tax -Capital or revenue -Mesne profits — Income from house property – Compensation for wrongful possession by its erstwhile tenant -Capital receipt [ S. 22, 25AA, 25B ]

Jayashree (Mrs.) v. ITO (2020) 427 ITR 209 (Mad) (HC)

S. 276CC : Offences and prosecutions – Failure to furnish return of income – Quashing complaint — Power of High Court — No power to consider facts [S.54F , Criminal Procedure Code, 1973, S. 482 ]

R. Mahalakshmi ( Smt). v ACIT (2020) 427 ITR 126 /193 DTR 313/ 273 Taxman 17 (Mad)(HC)

S. 271(1)(c) : Penalty – Concealment – Search and seizure -Block assessment – Penalty confirmed – Direction by CIT(A) regarding levy of penalty under S. 271AAA was rightly deleted by the Tribunal- Assessee has not challenged the levy of penalty u/s 271(1)( c ) of the Act . [ S. 153A,251, 271AAA]

Nahar Spinning Mills Ltd. v. CIT (2020) 427 ITR 131/193 DTR 161/ 274 Taxman 325/ (2021) 318 CTR 108 (P&H)(HC)

S. 263 : Commissioner – Revision of orders prejudicial to revenue –Duty drawback – Subject matter of appeal- Issue neither considered nor decided in appeal before Commissioner (Appeals) — Revision is held to be proper . [ S.80I,147 , 251 ]