Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Gujarat State Lion Conservation Society v. CIT (2022) 196 ITD 172 (Rajkot)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Government grants-Accumulation of income-Doctrine of consistency-Accumulation of 15%-Revision is not valid. [S. 11(1)(a), 12]

Shrigopal Rameshkumar Sales (P.) Ltd. v. ACIT (2022) 196 ITD 107 (Nagpur)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Search-Un explained expenditure-Cash paid to labour charges-No explanation was furnished-Revision is held to be valid. [S. 69C, 132, 153A]

Nuziveedu Seeds Ltd. v. DCIT (2022) 196 ITD 53 / 219 TTJ 1 (Hyd.)(Trib.)

S. 254(1) : Appellate Tribunal-Powers-Additional grounds-Farming genetically modified seeds in lands leased from farmers-Additional evidence filed by Revenue based on Search proceedings-Matter remanded. [S. 2(IA), 10(1), 132, 153A, ITAT R. 29]

Samira Habitats India Ltd. v. DCIT (2022) 196 ITD 561 (Mum.) (Trib.)

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Ex-parte order-Matter was remanded to Commissioner (Appeals) for fresh adjudication. [S. 144, 153C, 251]

Goldstone Trading Company (P.) Ltd. v. ACIT (2022) 196 ITD 556 (Mum.)(Trib.)

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Ex-parte order-Adjournment request was filed-Matter was to be remanded to Commissioner (Appeals) for adjudication de novo. [S. 251]

Marvel Industries Ltd. v. DCIT (2022) 196 ITD 229 / 218 TTJ 806/ 216 DTR 249 (Mum.)(Trib.)

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Ex-parte order-Even while passing the ex-parte order the CIT(A) has to deal with merits in respect of all issues raised in the grounds of appeal. [S. 144, 251]

Nitesh Estates Ltd. v. ADIT(IT) (2022) 196 ITD 404 / 220 TTJ 1003 / 220 DTR 277 (Bang.)(Trib.)

S. 195 : Deduction at source-Non-resident-Sale of property-Capital gains-Resident payee had reported income in ITR or did not have positive income in assessment year under consideration would not absolve assessee’s liability to deduct tax. [S. 201, 201(IA)]

Interocean Shipping (India) (P.) Ltd. v. DCIT(IT) (2022) 196 ITD 253 / 100 ITR 560 (Rajkot)(Trib.)

S. 172 : Shipping business-Non-residents-Shipping business-Option to be assessed under normal provision-Summary assessment orders passed under section 172(4) on each voyage undertaken earning freight from India is held to be not valid-DTAA-India-Greece. [S. 139, 172(4), 172(7), Art. 8]

Marlabs Innovations (P.) Ltd. v. DCIT (2022) 196 ITD 179 / 97 ITR 64 (SN) (Bang.)(Trib.)

S. 170 : Succession to business otherwise than on death-Amalgamation-Assessment order was passed in the name of company which is ceased to be in existence as on date when Assessing Officer passed order-Order is nullity. [S. 2(31), 143(3)]

Otis Elevator Company (India) Ltd. v. DCIT (2022) 196 ITD 558 (Mum.)(Trib.)

S. 154 : Rectification of mistake-Mistake apparent from the record-Interest-Revised return enhancing its TDS claim-Interest on refund-withdrawal of interest under section 244A(2) was beyond scope of rectification-Order of rectification was quashed and set aside. [S. 244A(2)]