Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Nayara Energy Ltd. v. ACIT (2024) 232 TTJ 353 / 244 DTR 89/ 38 NYPTTJ 1162 (Mum)(Trib)

S.28(1): Business loss-Transfer of inter-corporate deposits and liabilities to a sister concern for a lesser consideration-Loss is not allowable as deduction. [S.37(1)]

Dy. CIT v. Pooja Marketing (2024) 232 TTJ 4 (UO) (Chennai) (Trib)

S. 28(i): Business income-income from other sources-Prize money from unsold lottery tickets-Winnings from unsold lottery tickets are assessable as business income. [S.2(24)(ix), 56(2)(ib)]

Foundation for Ecological & Environmental Sustainability Trust v. CIT (E) (2024) 232 TTJ 210 / 38 NYPTTJ 1209 (Jodhpur)(Trib)

S. 12AA : Procedure for registration-Trust or institution-Contribution for establishment of a Dam from PHD Rural Development Foundation which is a social arm of PHD Chamber of Commerce and Industry—Not for profit-Matter is remanded to CIT(E) to decide whether activity is genuine or not. [S.2(15), 12AB, 13(3),80G (5)]

CIT (E) v. Shree Assistant Maheshwari Samaj (2024) 232 TTJ 17 (UO) (Jodhpur) (Trib)

S. 11 : Property held for charitable purposes-Rental income-Community hall-No profit motive-Object of general public utility-receipts from such activity do not exceed 20 per cent of the as total receipts, proviso to S. 2(15) is not applicable-Corpus donations-Direction to building fund-Exemption under section 11(1)(d) is applicable. [S. 2(15), 11(1)(d), 12, 12AA]

Church Educational Society v. ACIT (2024) 232 TTJ 553 / 244 DTR 193 / 38 NYPTTJ 1419 (Hyd)(Trib) Aurora Educational Society v. ACIT (2024) 232 TTJ 553 / 244 DTR 193 / 38 NYPTTJ 1419 (Hyd)(Trib) Karshik Vidya Parishad v.. ACIT (2024) 232 TTJ 553 / 244 DTR 193 / 38 NYPTTJ 1419 (Hyd)(Trib)

S. 11 : Property held for charitable purposes – Once exemption is denied and the registration is withdrawn the income of the trust should be assessed an AOP – Only surplus profit can be assessed – Application before CBDT for condonation of delay in filing Form No 10BB-The AO is directed to decide the issue of exemption after the order of the CBDT. [S. 12AA, 119, Form 10BB.]

ITO v. Managing Director, Davanagere Smart City Ltd. (2024) 232 TTJ 64 (UO) (Bang)(Trib)

S. 4 : Charge of income-tax-Interest on deposits of grants received by nodal agency of Government-Issue is remitted back to the AO to ascertain whether the interest income has been remitted back; if the entire interest income has been remitted back to the Central Government/State Government, then no addition is sustainable on account of the interest income earned on the deposits.[S. 5]

State Pollution Control Board v. ITO (2024) 232 TTJ 887 / 38 NYPTTJ 1390 (Cuttack)(Trib)

S. 4 : Charge of income-tax-Controlled financially as well as administratively by the State Government-Pollution Control Board established by State Act-Winding up the funds would revert to the State Government-Income is not taxable. [The Orissa Water (Prevention and Control of Pollution) (Amendment) Act, 1974, S.4(1), Art. 12, 289(1)]

Mohd. Wajahat Ali Khan v.ITO (IT) (2024) 231 TTJ 1082 / 242 DTR 51 / 38 NYPTTJ 648 (Hyd)(Trib)

S. 271F : Penalty-Return of income-Failure to furnish-Non-Resident-Pendency of appeal before Tribunal-Order passed by the CIT(A) confirming the levy of penalty is set aside and the issue is restored back to the AO-AO is directed to take up the issue of penalty after the disposal of the appeal filed by the assessee before the Tribunal and decide the issue in accordance with the law. [S.69A, 271(1)(b)]

Yamuna Power & Infrastructure Ltd. v. Dy.CIT : (2024) 231 TTJ 1059 / 243 DTR 33 / 38 NYPTTJ 956 (Chd)(Trib)

S. 271AA : Penalty-Failure to keep and maintain books of accounts-Documents-International transaction-Transfer pricing-Initiated on different grounds-Levied on different grounds-Had a reasonable basis for non-reporting such transactions-Levy of penalty is deleted.[S.92D, 273B]

Sree Navaladiyan Finance v.Dy.CIT (2024) 231 TTJ 192 (Chennai)(Trib)

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge-Penalty is deleted. [S.270A, 274]