Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Godwin Construction Pvt. Ltd. v. ACIT (2023)101 ITR 74 (SN) (Delhi) (Trib)

S. 68 : Cash credits-Burden of proof-Receipts of sums of deposits, receipts of sums refunded furnished by the assessee-Details not untrue-Burden discharged-Additions is not justified. [S.292C]

Ganesh Ginning Factory v .ACIT (2023)101 ITR 90 (SN) (Ahd) (Trib) Gajanand Ginning and Pressing Pvt. Ltd v.ITO (2023)101 ITR 90 (SN) (Ahd) (Trib) Premjibhai Vallabhbhai Kukadiya v. ITO (2023)101 ITR 90 (SN) (Ahd) (Trib)

S. 68: Cash credits-Assessee filed confirmation of parties and repayment-Matter Remanded for fresh adjudication.

ITO v. Mega Collections (P) Ltd(2023) 201 ITD 404(Surat)(Trib)

S. 68 : Cash credits-Unsecured loan-Proved identity, genuineness and creditworthiness of the loan transactions-Order of CIT(A) deleting the addition is affirmed.

Teleperformance BPO Holdings (P.) Ltd. v. NFAC (2023)200 ITD 60/ 222 TTJ 997 (Mum)(Trib.)

S. 60 : Transfer of income where there is no transfer of assets-Revocable transfer-Reduction of share capital and subsequently, conversion of FCD into equity shares-Written off its investment in its Profit and Loss account-There is no generation of income in the transaction of reduction in share capital and conversion of FCDs into shares-Addition is deleted.[S. 63]

Avantha Consulting Services Ltd. v. Dy. CIT (2023) 153 taxmann.com 182/ 104 ITR 723 (Delhi)(Trib)

S. 57 : Income from other sources-Deductions-Interest earned on fixed deposit-Nexus between expenditure incurred and the income earned [S.56,57(iii)]

Philia Estates Developers (P) Ltd. v. ACIT[2023] 201 ITD 239 /104 ITR 15 (SN) (Delhi) (Trib)

S. 57 : Income from other sources-Deductions-Compulsory acquisition of property-Interest on enhanced compensation -Assessable as income from other sources and not as business income – Real estate business is not relevant – Entitled to deduction of 50 Per Cent. .[S. 28(i), 56(2)(viii), 57(iv), 145B(1)]

ACIT (LTU) v. Tamilnadu Petroproducts Ltd. (2023) 103 ITR 92 (SN) (Chennai)(Trib)

S. 57 : Income from other sources —Deductions-Shortfall in sale consideration for transaction of Sale Of Equity Shares-Burden of fees paid for sale transaction claimed during year of sale-Genuineness of expenditure not in doubt and facts narrated by assessee found correct-Not to be disallowed merely because paid in earlier year.[S.56(2), 57(1)]

RKM Powergen P. Ltd. v. Asst. CIT (2023)105 ITR 68 (SN)(Chennai)(Trib)

S. 56 : Income from other sources-Assessee’s plant at pre-operation stage, interest accruing on fixed deposits after business set up, deposits linked with projects would not alter character of income after business set up. [S. 28(i)]

CNR Leading Softek P. Ltd. v .ITO (2023)104 ITR 26 (SN)(Delhi)(Trib)

S. 56 : Income from other sources-Share premium-Valuation of shares-Share premium reflected in balance-sheet-Figures reflected in books of account or in balance-sheet prepared in accordance with Companies Act, 1956-AO does not have power to disturb-Share premium to be included in “reserves and surplus”-AO under “liability approach” ignoring share premium in balance-sheet under “reserve and surplus”-Under “asset approach”, treating share premium as liability-Both workings flawed-Net asset value method adopted by assessee recognised method-Taxation of share premium u/s. 56(2)(viib) of the Act is only by way of deeming fiction.-Addition unsustainable: [S. 56(2)(viib),Rule ,11UA]

Ajay Kothari v. ITO (Mum)(Trib.) (UR)

S. 56 : Income from other sources-Redevelopment-Rent-Alternative accommodation-Rent Received from builders on account of redevelopment for alternate accommodation-Hardship allowance-Not taxable as income from other sources.[S. 4]