Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


PCIT v. Vardhan Builders (2023) 155 taxmann.com 391/ (2024) 296 Taxman 1 (SC) Editorial : PCIT v. Vardhan Builders (2023) 291 Taxman 45/ 456 ITR 310(Bom)(HC)

S. 80IB(10) : Housing projects-Built up area less than 1000 sq.ft-Deduction claimed on basis of approved plans of BMC, occupancy certificate issued by BMC-High Court affirmed the order of Tribunal-SLP of Revenue is dismissed. [Art. 136]

PCIT. v. Hadoti Punj Vikas Ltd (2024) 296 Taxman 248 (SC) Editorial: Pr. CIT v. Oriental Power Cables Ltd. [2022] 143 taxmann.com 370 (Raj.) (HC)

S. 68 : Cash credits-Opportunity to cross examination was not given-Produced affidavit of lenders and notice issued was complied with-High Court affirmed the order of the Tribunal deleting the addition-SLP of Revenue is dismissed. [S. 131, 133(6), Art. 136]

CIT v. Ad2pro Media Solutions (P.) Ltd. (2024) 296 Taxman 569/ 463 ITR 700 (SC) Editorial : Refer, CIT v. Ad2pro Media Solutions (P.) Ltd (2023) 148 taxmann.com 226/ 455 ITR 648 (Karn)(HC)

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services Deduction of tax at source-Payment to non-resident-Foreign company had not rendered technical services to Indian company-Amount remitted not taxable-Not liable to deduct tax at source-SLP of Revenue is dismissed-DTAA-India-United States of America. [S. 195, 201(1), 201(IA), Art. 12(4), Art. 32]

Asst. CIT v. Vinay Diamonds (2023) 105 ITR 31 (SN) (Surat) (Trib)

S. 271-I: Penalty-Deduction of tax at source-Remittances against import of goods-provision for withholding tax and requirement to furnish details not mandatory-forms 15CA and 15CB to be submitted only for payments chargeable to tax in India-Penalty not attracted for failure to furnish forms. [S. 195(6), Form,15CA,15CB,Rule 37BB]

Jagdish Chandra Suwalka v. Jt. CIT (2023) 154 taxmann.com 504/ 105 ITR 480 / 225 TTJ 161 (SMC)(Jaipur) (Trib)

S. 271D : Penalty-Takes or accepts any loan or deposit-Penalty could not be imposed after expiry of period of limitation.[S. 275(1)((c)]

Kundan Industries Ltd. v. JCIT(TDS) (Mum)(Trib) (UR)

S. 271C : Penalty-Failure to deduct at source-Tax deducted at source-Deposited with interest-Survey-Reasonable cause-Levy of penalty is not justified.[S.133A]

Yes Bank Ltd. v Add. CIT (TDS) (2023)101 ITR 13 (SN) (Dehradun) (Trib)

S. 271C : Penalty-Failure to deduct at source-Interest payable to Uttarakhand Environment Protection and Pollution Control Board on FDs with the assessee-Board not a taxable entity, established under Central Act-Penalty not leviable. [S. 194A(3)(iii)(f), Notification No. S. O. 3489(E), Dated 22-10-1970.]

Gill Rice Mill Guru Sar Sahnewala v. Dy. CIT (2023) 105 ITR 717 (Amritsar)(Trib)

S.271B: Penalty-Failure to get accounts audited-Delay in filing audit report due to change of tax auditor-Reasonable cause for delay-Penalty cannot be levied

Jigneshbhai Rasikbhai Savalia v. ITO (2023) 200 ITD 271 / 224 TTJ 907 (SMC) (Surat) (Trib)

S. 271B : Penalty-Failure to get accounts audited-Audit report filed along with the return-Levy of penalty is not justified.

Sonia Verma v. ITO (2023) 200 ITD 1/103 ITR 282/ 223 TTJ 870 (SMC)(Chd) (Trib)

S. 271D : Penalty-Takes or accepts any loan or deposit-Sale of flat-assessee collecting sale proceeds and also purchasing for daughter’s wedding-Failure on part of assessee reasonable-Words, “reasonable cause” and “Reasonable” to be taken into consideration as per 273B-Held, a penalty not to be imposed. [S. 273B]