Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Morbi Plot Jain Tapgachh Sangh v. CIT (2021) 433 ITR 1 / 202 DTR 385 / 321 CTR 198 (Guj.)(HC)

S. 12A : Registration-Trust-Exemption cannot be denied merely because certificate could not be produced as the same was destroyed during folds of 1978-Matter remanded. [S. 11, 12A, 12AA and 143(3)]

Bharathakshemam v. PCIT (2021) 320 CTR 198 / 199 DTR 113 (Ker.)(HC)

S. 11 : Property held for charitable purposes-Income from business or business held in trust-Main object is for establishing, maintaining and running a hospital for philanthropic purposes and not for the purpose of profit-Entitle exemption. [S. 2(15)]

PCIT v. HCL Comnet Systems And Services Ltd. (2021) 433 ITR 251 (Delhi)(HC)

S. 10A : Free trade zone-Export turnover-Telecommunication expenses and foreign currency expenditure not to be excluded from export turnover.

CIT v. Ambika Cotton Mills Ltd. (2021)433 ITR 193 / 279 Taxman 405 (Mad.)(HC) Editorial : Order in Ambika Cotton Mills Ltd. v Dy. CIT (2013) 27 ITR 44 (Chennai)(Trib.) is affirmed.

S. 4 : Charge of income-tax-Carban credit-Capital or revenue-sale of certified emission reduction credit, which the assessee earned on the clean development mechanism in its wind energy operations, was a capital receipt and not taxable.

Ankit Kapoor v. ITO ( 2021 ) 205 DTR 21/ 322 CTR 208/ ( 2022) 440 ITR 386 ( Delhi ) (HC)

S. 254(2)): Appellate Tribunal – Rectification of mistake apparent from the record-Duties – High Court directed the Appellate Tribunal to upload the daily order sheets and revised cause list on its website – System in this regard be put in place by the ITAT , if not already there as expeditiously as possible , preferable within three months [ S. 253 , 254(1), 255 , , ITAT Rules ,1963 19, 20Art . 226 ]

PCIT v. Cinestaan Entertainment Pvt. Ltd. (2021) 433 ITR 82/ 199 DTR 345/ 320 CTR 381 (Delhi) (HC) Editorial : Order of Tribunal in PCIT v. Cinestaan Entertainment Pvt. Ltd (2019) 180 DTR 65/ 200 TTJ 459 / 177 ITD 809 (Delhi)(Trib.),affirmed .

S. 56 : Income from other sources – DCF Method – Receipt of consideration for issue of shares in excess of their market value – Valuation of shares- Following the prescribed method – Addition based on estimate is held to be not justified – Deletion of addition is held to be justified [ S.56 (2)(viib ) , 68, R 11UA (2)(b) ]

PCIT v. Sahara India Life Insurance Co. Ltd. (2021) 432 ITR 84 (Delhi) (HC)

S. 271(1)(c) : Penalty-Concealment-Notice-Not mentioning the specific charge for concealment of income or furnishing inaccurate particulars of income-Deletion of penalty is held to be justified.

Karur Vysya Bank Ltd. v. PCIT (2021) 432 ITR 622/ 281 Taxman 532 / 207 DTR 54/ 323 CTR 429 (Mad.)(HC)

S. 264 : Commissioner-Revision of other orders-Fringe Benefits Tax-Claim for refund based on order of Tribunal-Commissioner bound by circular-Limitation does not apply to CBDT for passing order u/s 119-Principle of fairness and reasonableness is constitutional mandate-CBDT is directed to entertain the application for grant of refund. [S. 115WD(4), 119,Art, 14, 164]

PCIT v. Zuari Maroc Phosphates Ltd. (2021) 432 ITR 316 / 279 Taxman 333 (Goa) (Bom.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Carry forward of loss-Acceptance of claim Of without application of mind to material on record-Revision of order setting aside the Assessment order is held to be justified. [S. 37(1), 72]

Karnataka Financial Services Ltd. v. ACIT (2021) 432 ITR 187 (Karn.) (HC)

S. 260A : Appeal-High Court-Remand to Tribunal by High Court-Block assessment-Limitation-Question of limitation can be raised before the Tribunal in remand proceedings-Matter remanded to the Tribunal. [S. 132, 158BC, 254(1)]