Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


IFCI Factors Ltd. v. Bank of India (2022) 289 Taxman 654 /(2023) 455 ITR 705 (Delhi)(HC)

S. 226 : Collection and recovery-Modes of recovery-Priority over debts-FDR to secure payment of debt-Secured creditor-Priority over Income Tax department who is an unsecured creditor. [Securities Contracts (Regulation) Act, 1956, 8, 9]

Urban Improvement Trust v. ACIT (2022) 142 taxmann.com 239 (Raj.)(HC) Editorial : SLP dismissed as withdrawn, Urban Improvement Trust v. ACIT (2022) 289 Taxman 2 (SC)

S. 220 : Collection and recovery-Assessee deemed in default-Stay of demand-Directed to deposit 20 percent of demand sum-Recovery proceedings was stayed. [S. 220(6), Art. 226]

PCIT v. Nirmal Kumar Kejriwal (2022) 289 Taxman 51 / 216 DTR 441/ 328 CTR 222 / ( 2023) 454 ITR 777 (Cal.)(HC)

S. 206C : Collection at source-Trading-Forest produce-Trading of timber sawn into logs of different dimensions and shapes which was imported from other countries-Timber sold by assessee would not amount to forest produce and, thus, provisions of section 206C(1) were not applicable on same. [S. 206(1)]

CIT v. Air India Ltd. (2022) 289 Taxman 492/(2023) 456 ITR 117 (Delhi)(HC). Editorial: SLP of Revenue dismissed , CIT (IT) Air India Ltd ( 2023 ) 456 ITR 139/294 Taxman 163 ( SC)

S. 206AA : Requirement to furnish Permanent Account Number-Non-Resident-Provisions cannot have overriding effect on DTAA-Rates prescribed under DTAA are applicable-DTAA-India-Netherland. [S. 2(37A)(iii), 4, 5, 9(1)(i), 90(2), 206AA(7), Art. 12(4)]

Chetna Jain. (Smt.) v. CIT (2022) 289 Taxman 549/ 220 DTR 417/(2023) 332 CTR 866 (Cal.)(HC)

S. 199 : Deduction at source-Credit for tax deducted-Rectification of application was directed to be allowed-Matter remanded to the Appellate Authority to decide afresh. [S. 154]

New India Assurance Company Ltd. v. Ravinder Kumar @ Vickey. (2022) 289 Taxman 497/223 DTR 16 / (2023) 331 CTR 272 (P& H)(HC)

S. 194A : Deduction at source-Interest other than interest on securities-Interest on compensation-Motor Accidents Claims Tribunal award-TDS cannot be deducted by insurance companies on interest on compensation with effect from 1-6-2015 even if interest is beyond Rs. 50,000 in a particular year. [S. 2(24), 2(28A), 56(2), Form 15G, Rule, 29C, Motor Vehicle, Act. 1988]

PCIT v. Sunway Realtech (P.) Ltd. (2022) 289 Taxman 543 /(2023) 457 ITR 123(Delhi)(HC)

S. 153C : Assessment-Income of any other person-Search-Unexplained investment-Share transaction-No incriminating material was found in the course of search-Addition cannot be made. [S. 69]

PCIT v. Suman Agarwal (Ms) (2022) 289 Taxman 674 /(2023)451 ITR 364 (Delhi)(HC)

S. 153A : Assessment-Search or requisition-Long term capital gains on sale of shares-No incriminating material was found-Merely on the basis of statement of and letter of Managing Director of company-Addition cannot be made. [S. 10(38), 68]

PCIT v. Shiv Kumar Agarwal (2022) 289 Taxman 278 (Delhi)(HC)

S. 153A : Assessment-Search or requisition-Cash credit-Capital gain-Sale of shares-Incriminating material-When no incriminating material found during course of search and AO had made additions solely relying on disclosures made by Managing Director of a company on which search was conducted, impugned addition was unjustified. [S. 10(38), 45, 68]

South Asian Stocks Ltd. v. ACIT (2022) 289 Taxman 33 (Delhi)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Shares-SEBI registered broker-Information was not reported by the Assessing Officer of Vishesht Financial Services Pvt. Ltd. (VFSPL) to assessee’s Assessing Officer-Notice was set aside and matter was to be remanded to Assessing Officer to pass a fresh order-Matter remanded. [S. 69, 147, 148, 148A(d), Art. 226]