Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Meda Raja Kishor Raghuramy Reddy. v. ACIT (2024) 205 ITD 715 /113 ITR 258 (Panaji) (Trib.)

S. 250 : Appeal-Commissioner (Appeals)-Non-speaking order-Procedure-Commissioner (Appeals) has to decide appeal on merit by passing a speaking order and does not have any power to dismiss appeal for non-prosecution.[S.68, 69, 131, 133(6), R.46A]

Rajkumar Anandchand Jain. v. DCIT (2024) 205 ITD 14 (Mum) (Trib.)

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Income from other sources-Appeal is dismissed without deciding on merits-Matter remanded to the file of CIT(A) to decide on appeal. [S.56(2)(x)(b), 250(6)]

Sony India (P.) Ltd v. Dy.CIT (2024) 205 ITD 194 /227 TTJ 619(Delhi)(Trib)

S. 220 : Collection and recovery-Assessee deemed in default-Fringe Benefit tax-Intimation and demand notice concerning FBT demand was ever served-Interest charged under section 220(2) is deleted. [S.115WE, 115WJ,220(2)]

ACIT v. Indian Institute of Technology. (2024) 205 ITD 305 (Delhi) (Trib.)

S. 201 : Deduction at source-Failure to deduct or pay-Salaries-Perquisite-Rent free accommodation-Concession-No finding is recorded-Addition is deleted. [S.17(2)(ii), 201(1) R. 3]

FSL Projects Ltd. v. DCIT (2024) 205 ITD 530 (Hyd) (Trib.)

S. 195 :Deduction at source-Non-resident-Certificate-Survey-Subsequent issue of certificate-Entire remittances that were made to said concern would be non-taxable so far as TDS is concerned-Matter is remanded. [S.133A, 195(3), 201(IA)]

Bharat Sanchar Nigam Ltd. v. DCIT (2024) 205 ITD 318 (Rajkot) (Trib.)

S. 194H : Deduction at source-Commission or brokerage-Discount- Deducted taxes at appropriate rates at time of giving trade discount/commission to it’s agents-Cannot be held to be an assessee-in-default-Matter remanded to the file of CIT(A). [S. 194C, 194J, 201 (1), 201(IA)]

Shital Bachubhai Vaidya. v. ADIT (2024) 205 ITD 42 (Ahd) (Trib.)

S. 154 : Rectification of mistake-Mistake apparent from the record-Interest income from Government securities Commissioner (Appeals) was to be directed to carry out necessary verifications and if claim of assessee was found to be correct, relief was to be allowed to assessee in accordance with law. [S. 10(15),143(1), 250]

Poonam Promoters and Developers (P.) Ltd. v. ACIT (2024) 205 ITD 534 (Delhi) (Trib.)

S. 153A: Assessment-Search-No incriminating material was found during search-Addition is deleted.[S. 132]

Ashish Jain. v. DCIT (2024) 111 ITR 152 / 205 ITD 455/228 TTJ 405 (Chd) (Trib.) Bipin Jain v. DCIT (2024) 111 ITR 152 / 205 ITD 455 /228 TTJ 405 (Chd) (Trib.) Akil Jain v. DCIT (2024) 111 ITR 152 / 205 ITD 455 /228 TTJ 405 (Chd) (Trib.)

S. 153A : Assessment-Search-Share certificates and contract notes seized-Not incriminating in nature-Capital gains-Addition as cash credit is not justified-Entitle to exemption. [S. 10(38), 45, 68, 132]

Sutherland Global Services Inc. v. ACIT (IT) (2024) 205 ITD 270 (Chennai)(Trib)

S. 144C : Reference to dispute resolution panel-Document Identification Number (DIN)-Order passed by DRP without a valid computer-generated Document Identification Number (DIN)-Illegal and non-est and deemed to have never been issued-Assessment order passed by Assessing Officer in pursuance to DRP’s order was bad in law and quashed. [S.144C(13)]