Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


PCIT v. Vikas Telecom Ltd. (2022) 286 Taxman 238 / 209 DTR 373 / 324 CTR 341 (Delhi)(HC)

S. 68 : Cash credits-Shares of Raj Darbar Group brought back the shares at much lower rate at which the shares were allotted-Addition was made not on the basis of seized materials or statements-Deletion is held to be justified. [S. 132, 153C]

PCIT v. Inland Road Transport Ltd. (2022) 286 Taxman 613 (Cal.)(HC)

S. 68 : Cash credits-Unsecured loans-Established genuineness and credit worthiness-Deletion of addition was justified.

PCIT v. AHW Steels Ltd. (2022) 286 Taxman 330 /( 2023) 450 ITR 709 (Cal)(HC)

S. 68 : Cash credits-Reconciliation of statement-Supported by evidence-Order of Tribunal was affirmed. [S. 260A]

PCIT v. CPC Logistics Ltd. (2022) 286 Taman 38 (Karn.)(HC)

S. 48 : Capital gains-Sale consideration-Fair market value deemed to be full value of consideration in certain shares-Transfer of a plot of land-Joint Development agreement-Not ascertainable-Guidance value of land would be appropriate mode to determine full value of consideration-Provision of section 50D came in to force with effect from 1-4-2013 is not applicable for the year under consideration. [S. 45, 50D]

PCIT v. Shelter Project Ltd. (2022) 445 ITR 291 / 286 Taxman 392 (Cal.)(HC)

S. 45 : Capital gains-Transfer-Immovable property-Unregistered agreement-Joint development agreement-Payment from developer-Not assessable as capital gains [S. 2(47)(v), Transfer of Property Act, 1882, S. 53A]

Dinesh Vazirani v. PCIT (2022)445 ITR 110/ 288 Taxman 325/ (2024) 337 CTR 380 (Bom.)(HC)

S. 45 : Capital gains Full value of consideration-Deductions -Consideration on sale shares including sum held in Escrow Account offered to tax-Receiving reduced sum from Escrow Account after Completion of assessment-Whole amount credited in book not taxable as capital gains-Only actual amount received taxable-Entitled to refund of excess tax paid-Recomputation can be less than the returned income-Proviso to section 240 is not applicable-The assessee can be asked to pay only such amount of tax which is legally due under the Act and noting more-Entitle to refund of excess tax paid [S. 48, 264, Art, 226]

PCIT v. Zuberi Engineering Co. (2022) 286 Taxman 686 (Raj.)(HC)

S. 43B : Deductions on actual payment-Service tax-Deduction available on actual payment.

PCIT v. Kerala State Electricity Board (2022) 137 taxmann.com 85 (Ker.)(HC) Editorial : Notice issued in SLP filed by Revenue, PCIT v. Kerala State Electricity Board. (2022) 286 Taxman 438 (SC)

S. 43B : Deductions on actual payment-Statutory corporation-Obligation of agent to account for and pay amounts collected by him on behalf of principal is purely fiduciary-Disallowance is not valid. [Electricity Supply Act, 1948, S. 5]

PCIT v. Bramha Corp Hotels and Resorts Ltd(2022) 136 taxmann.com 398 (Bom.)(HC) Editorial : SLP filed against order of High Court was to be dismissed as withdrawn. PCIT v. Bramha Corp Hotels and Resorts Ltd. (2022) 286 Taxman 265 (SC)

S. 43B : Deductions on actual payment-Employees’ and employers contribution-Paid before due date of filing of return-Allowable as deduction. [S. 139(1)]

CIT v. Tamil Nadu Water Investment Co. Ltd. (2022) 446 ITR 546 /286 Taxman 600 (Mad.)(HC)

S. 43B : Deductions on actual payment-Loan from its two promoters, Government of Tamil Nadu and IL&FS-Public financial institutions-Matter remanded to Assessing Officer. [S. 254(1)]