Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Betts India (P.) Ltd. v. ACIT [2020] 114 taxmann.com 509 (Bom)( HC)

S. 80IB: Industrial undertakings – Computation of deduction- Depreciation- Mandatory to deduct depreciation , though not claimed by assessee.[ S. 32 ]

ACIT v. Alfran Construction P. Ltd. [2020] 116 taxmann.com 125 (Bom)( HC)

S. 40(a)(ia): Amounts not deductible – Deduction at source -Agreement with co -owners of land for construction of complex – Allotment of area – Not contractor –Sub -Contractor- Not liable to deduct tax at source .[ S.80G , 194C ]

PCIT v. Manoj Parmar (2024) 300 Taxman 76 (Cal.)(HC) Editorial : Manoj Parmar v.UOI (W.P.No. 756 of 2007 dt. 17-3-2023 (Cal)(HC)

Article : 226 : Power of High Courts to issue certain writs-Rent-Rent in terms of CPWD revisions for period from 31-1-1994 to 30-6-2021-Single Judge took note of rent which was calculated according to recognized principles of valuation and there was no dispute which required any adjudication in matter, writ petition was maintainable and rightly entertained by Single Judge and directions issued therein deserved to be sustained. [Art. 226]

Aman Pathak v. Chief ITC (2024) 300 Taxman 589 (SC) Editorial : Aman Pathak v. Chief ITC (2024) 166 taxmmann.com 250 (Pat)(HC)

Constitution of India.

Article 136 : Special Leave to appeal by the Supreme Court-Lease of premises-Bid disqualified-Building Hiring Committee, which assessed premises suitability through technical bids and an on-site visit-Disqualification is held to be justified-Writ petition is dismissed-SLP is dismissed.

Sanjay Vijay Shinde v. Directorate GIT (2024) 300 Taxman 567 (MP)(HC)

Black Money (Undisclosed Foreign Income and Assets) and Imposition of tax Act, 2015.
S. 50 : Punishment for failure to furnish in return of income, any information about an asset (Including financial interest in any entity) located outside India-Punishment for wilful attempt to evade tax-Anticipatory Bail [S. 3(1), 10, 51, IT Act, 132,Criminal Procedure Code, 1973, 438

UOI v. D.N. Homes (P.) Ltd. (2024) 300 Taxman 98/ 469 ITR 2 (SC) Editorial : D.N. Homes (P.) Ltd v. UOI (2023) 156 taxmann.com 169/ 459 ITR 211 /335 CTR 942 (Orissa)(HC)

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Offences and prosecutions-Failure to pay to the credit tax deducted at source-Sanction for prosecution-Reasonable cause-Failure to deposit tax deducted at source due to prevalence of pandemic-Reasonable cause shown for failure-Sufficient cause-Assessee depositing tax deducted at source in phased manner with interest though after delay-Prosecution orders set aside-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 2(35), 276B, 278AA, 278B, 279, Art. 136]

S. Duraisamy v. Dy. CIT (2024) 300 Taxman 548 /243 DTR 204 (Mad.)(HC)

S. 271(1)(c) : Penalty-Concealment-Revised return filed voluntarily-Search-No deliberate or wilful omission on part of assessee-Review petition is allowed-Professional doctor and levying penalty on him would effect his mental status as well as professional career, order of Tribunal sustaining levy of penalty is set aside.[S. 132, 139(5), 148, 260A, Civil Procedure Code, 1908, Order XLVII of Rule 1]

PCIT v. Unitech Reliable Projects (P.) Ltd. (2024) 300 Taxman 585/ 469 ITR 394 (SC) Editorial : PCIT v. Unitech Reliable Projects (P.) Ltd (2023) 294 Taxman 507/ (2024) 462 ITR 307 (Delhi)(HC)

S. 271(1)(c) : Penalty-Concealment-Not specifying the specific charge-High Court affirmed the order Tribunal-SLP of Revenue is dismissed. [S. 274, Art. 136]

PCIT v. Shyam Sunder Jindal (2024) 300 Taxman 90 (SC) Editorial : PCIT v. Shyam Sunder Jindal (2024) 296 Taxman 115/ 462 ITR 501 (Delhi)(HC)

S. 271(1)(c) : Penalty-Concealment-Not specifying the specific limb-Delay of 202 days-Delay is not satisfactorily explained-SLP of Revenue is dismissed.[Art. 136]

Chhattisgarh State Minor Forest Produce (Trading and Development) Co-operative Federation Ltd. v. PCIT (2024) 300 Taxman 202 (Chhattisgarh)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-After initiating proceedings Commissioner is required to conduct enquiry-Reasons for satisfaction or non-satisfaction are required to be recorded-Procedure is not followed-Order of Tribunal affirming the Revision is set aside-Matter remanded back to Commissioner to reconsider the reply and the documents of assessee.[S. 260A]