Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Anuradha Wadhwa v. PCIT (2022) 142 taxmann.com 185 (All.)(HC) Editorial : SLP of assessee dismissed, Anuradha Wadhwa v. PCIT (2022) 289 Taxman 4 (SC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Opportunity of being heard-Participated in subsequent proceedings-Writ petition against revision proceedings was held to be not maintainable. [S. 143(3), 253, Art. 226]

PCIT v. LDS City Projects (P.) Ltd. (2022) 289 Taxman 484 (Cal.)(HC)

S. 254(1) : Appellate Tribunal-Duties-Cash credits-Share application money-Short term unsecured loan-Failure to record reasons-Matter was remanded to Tribunal. [S. 68]

PCIT v. Crystal Crop Protection (P.) Ltd. (2022) 289 Taxman 289 (Delhi)(HC)

S. 254(1) : Appellate Tribunal-Powers-Additional grounds-Excise duty, subsidy-Shown as revenue receipt-Tribunal was justified in admitting additional grounds. [S. 4]

Pala Marketing Co-operative Society Ltd. v. CIT (2022) 289 Taxman 271/(2023) 333 CTR 310 (Ker.)(HC)

S. 244A : Refunds-Interest on refunds-Excess advance tax and TDS-Delay in filing refund application was condoned-Period when application was pending adjudication before writ Court could not be attributed to department-Assessee was not entitle interest on refunded amount for said time period. [S. 119(2)(b), Art. 226]

BMW India (P) Ltd. v. Dy. CIT (2022) 289 Taxman 39 /(2023)) 450 ITR 695 (P& H)(HC)

S. 240 : Refunds-Appeal-Depreciation-Amount deposited when the appeal was pending before ITAT-Failure to pass fresh assessment order officer-Directed to refund excess amount deposited after deduction tax liability on depreciation allowance. [S. 143(3), 153, Art. 226]

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Urban Improvement Trust v. ACIT (2022) 142 taxmann.com 239 (Raj.)(HC) Editorial : SLP dismissed as withdrawn, Urban Improvement Trust v. ACIT (2022) 289 Taxman 2 (SC)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