Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


CIT v. I.T.C. Ltd. (2015) 64 taxmann.com 486 / (2024) 461 ITR 449 (Cal)(HC) Editorial : CIT v. I.T.C.Ltd (2024) 461 ITR 446 (SC), order of High Court is set aside and remanded for fresh disposal on merits.

S. 234A : Interest-Default in furnishing return of income-Self assessment tax paid was to be deducted from the tax payable as per the assessment order for the purposes of calculating interest payable-No substantial question of law.[S. 140A, 260A]

Tata Steel Ltd. v. Dy.CIT (2023) 156 taxmann.com 104/(2024) 460 ITR 595 (Delhi HC)]

S. 221 : Collection and recovery-Penalty-Tax in default-Dues payable to creditors for periods preceding the date of approval of the Resolution Plan can only be paid as per terms contained therein and therefore, demand recovery notices and consequent orders issued for preceding period are unsustainable in law and unenforceable. [143(3), 147, 148, 153A, 221(1), 271(1)(c), Insolvency and Bankruptcy Code, 2016., S. 31, 238, Art. 226]

G. K. Reddy v. Dy. CIT (No. 2) (2024) 461 ITR 104 (Mad)(HC) Editorial: Refer, G. K. Reddy v. DCIT (2023) 461 ITR 42/ 156 taxmann.com 729 (Mad)(HC)

S. 220 : Collection and recovery-Assessee deemed in default-Stay–Attachment of bank accounts-Attachment of bank accounts-Attachment of pension account to recover the outstanding dues-not justified.

G. K. Reddy v. DCIT (No. 1) (2023) 461 ITR 42/ 156 taxmann.com 729 (Mad)(HC) Editorial: Refer G. K. Reddy v. Dy. CIT (No. 2) [2024] 461 ITR 104 (Mad)(HC)

S. 220: Collection and recovery-Assessee deemed in default-Stay-Attachment of bank accounts–The Revenue was directed to lift attachment so far as pension of the assessee concern and he was allowed to withdraw pension-Embargo on the petitioner from withdrawing any other amounts deposited in the attached account was continued with direction to appellate commissioner to dispose appeals within 3 months from the date of the High Court’s order.[Art. 226]

CIT (TDS) v. Lalitpur Power Generation Co. Ltd. (2024) 296 Taxman 372/ 336 CTR 239 (All)(HC)/CIT v. Bajaj Energy (P) Ltd ( 2024) 296 Taxman 372 / 336 CTR 239 (All)(HC) CIT v. Bajaj Infrastructure Development Co .Ltd (2024) 296 Taxman 372 / 336 CTR 239 (All)(HC)

S. 194C : Deduction at source-Contractors-Work contracts-Payments for testing and commissioning of BTG and to CIPL for installation and commissioning of BOP-Rightly deducted under section 194C and not under section 194J [S. 194J,201]

A.2979 Thirumohur Primary Agricultural Co-operative Credit Society Ltd. and Others v. ITO (2024)461 ITR 69 (Mad)(HC)

S. 194N : Payment of certain amounts in cash-Withdrawal of cash in excess of Rs. 1 crore-Representation to Government-The High Court directed the MOF and CBDT to examine representation, call for related details/supporting documents, provide full opportunity of hearing to all stakeholders and pass reasoned order dealing with each contentions in accordance with law and until such exercise is taken, restrain from taking any coercive recovery u/s. 194H of the Act.[S. 119, Art. 226]

PCIT v. Maahi Milk Producer Co. Ltd. (2024) 460 ITR 222 (Guj) HC)

S. 194C: Deduction at source-Contractors-Technical services-Processing of milk attracts deduction of tax at source under section 194C at 2 per cent is rightly deducted-Order of Tribunal is affirmed.[S. 40(a)(ia), 194J, 260A]

Bhailal Babubhai Patel v. PCIT (2024) 460 ITR 226 (Guj (HC)

S. 179 : Private company-Liability of directors-Order against Ex-director of company-No steps were taken to recover dues from the company-Order is set aside. [Art. 226]

Pandian Anbalagan v. ITO (Mad.)(2024) 296 Taxman 499 (Mad)(HC)

S. 176 : Discontinued Business—Company struck off from official register of companies-Reassessment-Directors-Reassessment proceedings against the Directors in case of struck companies. S. 176 is applicable only when the company has discontinued the business. [S. 147, 148, 176(5), 176(7), Companies Act Art. 226]

CIT (IT) v. Heidrick and Struggles Inc. (2024) 461ITR 33 (Delhi)(HC) Editorial : Followed CBDT Circular 14 of 1995 dated 11.04.1995. Referred CIT v. Bharat General Reinsurance Co. Ltd. (1971)81 ITR 303 (Delhi)(HC)

S. 154 : Rectification of mistake-Mistake apparent from the record-Inadvertently disclosed income in its return-Return was accepted u/s. 139(1)-Rectification is rejected-Tribunal allowing the claim-Dismissing the appeal the Court held that merely because respondent included the income in the return as taxable cannot make it amenable to imposition of tax-DTAA-India-USA [. S. 139(1),143(1), 260A, Art. 14]