Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Advantage Strategic Consulting Pvt. Ltd. v. PCIT (2021) 430 ITR 1/ 277 Taxman 512 / 202 DTR 441 /(2022) 328 CTR 361 (Mad.)(HC)

S. 127 : Power to transfer cases-Interim order permitting continuation of writ proceedings- Assessment completed-Appeal became infructuous-Duty of assessee to pay tax- Comply with order or file an appeal. [Art. 226]

CIT v. Wipro Ltd. (2021) 430 ITR 34/ 279 Taxman 253 (Karn.)(HC)

S. 115WB : Fringe benefits-Sponsoring students for higher education-No relationship of employer and employee-Amounts spent on bundling of product-Not liable to be assessed as Fringe benefits-Reimbursement of medical expenses to employees in excess of fifteen thousand rupees liable to Fringe benefits. [S.17(2)(v)]

PCIT v. Redington (India) Ltd. (2021) 430 ITR 298/197 DTR 233/ 318 ITR 520 (Mad.)( HC)

S. 92C : Transfer pricing-Arm’s length price-Amount paid as trade mark fees to associated company in Singapore-Trade Mark was being used for several years past-Disallowance of trade mark fees is held to be justified-Corporate and Bank guarantees-Financial services- Direction to modify the claim is justified-Clarificatory Amendment can have retrospective operation. [S. 47(iv), 92B]

CIT v. Tidel Park Ltd. (No. 1) (2021) 430 ITR 214 (Mad.)(HC)

S. 80IA : Industrial undertakings- Infrastructure development-Development and leasing of premises in software park-Assessable as business income- Entitle to deduction. [S. 28(i), 80IA(4)]

Sesa Goa Ltd. v. CIT (NO. 1) (2021)430 ITR 109 (Bom.)(HC)

S. 80HHC : Export business-Shipping agency fees, hire charges of machinery and installation must be reduced on net Basis-Proceeds of services and repairs by Shipyards not to be reduced. [S.80HHC Explanation (baa)]

C. V. Ravi v. ITO (2021) 430 ITR 449 / 279 Taxman 429 (Mad.)(HC) Editorial : SLP dismissed , C. V. Ravi v. ITO ( 2021 ) 281 Taxman 362 ( SC)

S. 68 : Cash credits- Burden to establish identity of creditors, genuineness of loan transaction and capacity of lender-Addition is held to be justified. [S. 260A]

CIT v. H. E. Panduranga (2021) 430 ITR 70/ 277 Taxman 480 (Karn.)(HC)

S. 68 : Cash credits- Block assessment- Matter remanded to the CIT (A) to consider unexplained cash credits . [S. 132, 143(3), 147, 158BA, 254(1)]

Alok Goenka v. CIT (2021)430 ITR 46 / 277 Taxman 527 / 207 DTR 235(Pat.)(HC)

S. 64 : Clubbing of income-Minor child-Interest from firm-Accounting year ended on December 31, 1975-Income cannot be clubbed for the relevant year. [S. 64(1)(iii), 66, 256(1)]

CIT v. Shriram Ownership Trust (2021) 430 ITR 356/197 DTR 153/ 318 CTR 233 (Mad.)(HC)

S. 56 : Income from other sources-Individual-Natural living individuals-Donation received by discretionary Trust-Assessable as income from other sources. [S. 2(24)(xv), 2(31)(v), 56(2)(vii)]

PCIT v. Redington (India) Ltd. (2021) 430 ITR 298 (Mad.)(HC)

S. 45 : Capital gains-Transfer of shares to subsidiary in Mauritius- Transfer of Shares from subsidiary to Private Equity Fund incorporated in Cayman Islands-Transactions are not genuine-High Court has the power to find out if transactions are genuine.