Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


CIT(IT) v. Reema Chawla (2024) 298 Taxman 704 (Delhi)(HC)

S. 54 : Capital gains-Profit on sale of property used for residence-Under construction flat-Possession had been completed within a three years from date of sale of residential house-Entitle to deduction. [S. 45, 260A]

CIT (IT) v. Technip France SAS (2024) 298 Taxman 119 (Delhi)(HC)

S. 44BB : Mineral oils-Computation-Payment received for providing various services in connection with mining activity would not be chargeable to tax as fees for technical services. [S. 9(1))(vii), 44AD]

Johnson and Johnson Ltd. v. Dy. CIT (2024) 298 Taxman 388 (Bom.)(HC)

S. 43B : Certain deductions only on actual payment-Excise duty-Included in closing stock-No double deduction-Allowable as deduction.[S.145, 260A]

Rajesh Kumar v. CIT (2024) 298 Taxman 753 / 463 ITR 328 (SC) Editorial : Rajesh Kumar v. CIT (2024) 296 Taxman 540/463 ITR 320 (Delhi)(HC)

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Genuineness of transaction was in doubt-Order of High Court is affirmed-SLP of assessee is dismissed. [R.6DD(j), Art. 136]

Indian Express Newspapers (Bombay) Ltd. v. CIT (2024) 298 Taxman 507(Bom.)(HC)

S. 37(1) : Business expenditure-Provision for salary and wages-Justice Palekar Award-Ex-gratia bonus-Allowable as expenditure. [S. 36(1)(ii), 260A, Payment of Bonus Act, 1965]

Market Committee v. ACIT (2024) 298 Taxman 473 /467 ITR 118 (P&H)(HC)

S. 37(1) : Business expenditure-Payment to Haryana State Agricultural Board-Statutory functioning-Application of income-Allowable as deduction-Penalty order is quashed as the quantum disallowance is deleted. [S.260A, 271(1(c)]

PCIT v. Industrial Development Corporation of Orissa Ltd. (2024) 298 Taxman 743 (SC) Editorial: PCIT v. Industrial Development Corporation of Orissa Ltd (2023) 147 taxmann.com 298 (Orissa)(HC)

S. 37(1) : Business expenditure-Cpmpensation-340 days delay-SLP is dismissed.[Art. 136]

Sharad Sahakari Sakhar Karkhana Ltd. v. CIT (2024) 298 Taxman 191/339 CTR 345 (SC) Editorial : CIT v. Tasgaon Taluka S.S.K Ltd (2019) 262 Taxman 176 // 412 ITR 420 / 307 CTR 473/ 175 DTR 345 (SC)

S. 37(1) : Business expenditure-Diversion by overriding title-Sharing of profit-The AO has to take into account the manner in which the business works, the modalities and manner in which SAP/additional purchase price/final price are decided and determine what amount forms part of the profit-Whatever is the profit component is sharing of profit/distribution of profit and the rest is deductible as expenditure-question of law is answered partly in favour of the revenue and partly in favour of the assessee-Matter is remitted to the AO to undertake the exercise as stated in the judgement after giving an opportunity to the respective assesses-Review petition is dismissed [S.40A(2),Sugarcane (Control) Order 1966 clauses, 3, 5A]

Zuari Management Services Ltd. v. CIT (2024) 298 Taxman 551 (SC) Editorial : Zuari Management Services Ltd. v. CIT (2017) 88 taxmann.com 625 (Bom)(HC)

S. 37(1) : Business expenditure-Interest-Real estate business-Not commenced the business-Investing in shares of subsidiary-Not allowable as deduction-SLP of assessee is dismissed.[Art.136]

Rohan Korgaonkar v. Dy. CIT (2024) 298 Taxman 159 (Bom.)(HC)

S. 36(1)(va) : Any sum received from employees-Late deposit of employee’s contribution to PF and ESI-Disallowance is justified-Assessment order under section 143(1)(a) would make no difference.[S.143(1)(a), 260A]