Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


CIT v. GMR Energy Ltd. (2021)437 ITR 240 (Karn.)(HC)

S. 36(1)(iii) : Interest on borrowed capital-Commercial expediency-Borrowed funds not diverted to sister concerns-Allowable as deduction. [S. 37(1)]

PCIT v. Petrofils Co-op. Ltd. (2021) 130 taxmann.com 190 (Guj.)(HC) Editorial : SLP of revenue was dismissed ; PCIT v. Petrofils Co-op. Ltd. (2021) 282 Taxman 319 (SC)

S. 32(2) : Depreciation-Unabsorbed depreciation-Set-off-Allowed to be carried forward and set off after a period of eight years without any limit as per section 32 (2) as amended by Finance Act, 2001. [S. 32]

PCIT v. H.D. Enterprises (2021) 130 taxmann.com 289 (Guj.)(HC) Editorial : SLP of revenue dismissed, PCIT v. H.D. Enterprises (2021) 282 Taxman 382 (SC)/) (2021 438 ITR 2 (ST) (SC)

S. 32 : Depreciation-Business of mining and transportation-Dumpers-Higher rate of depreciation of 30% is allowable-No substantial question of law. [S. 260A]

Apollo Tyres Ltd. v. Dy. CIT (2021) 438 ITR 526/ 283 Taxman 427 (Ker.)(HC)

S. 32 : Depreciation-Part of building let out to sister concern-Disallowance of depreciation is held to be justified. [S. 22]

CIT v. Tidel Park Ltd. (2021) 437 ITR 311 (Mad.)(HC)

S. 28(i) : Business income-Income earned by letting out of property for running software Technology park-Assessable as business income. [S. 22, 56]

Indian Institute of Science v. Dy. CIT (2021) 438 ITR 400 / 204 DTR 329/ 322 CTR 217 (Karn)(HC).Editorial: Affirrmed in Indian Institute of Science v .Dy. CIT (2022) 446 ITR 418 (SC)

S. 17(2) : Perquisite-Valuation of perquisites- Salary – Deduction at source -Rent as per Rule 3-Accommodation provided by Central Government and State Government to its employees-Not applicable to undertakings controlled by Central or State Governments. [S. 15, 192, ITR, 1962, R. 3]

Karur Vysya Bank Ltd. v. CIT (2021) 438 ITR 465 /(2022) 284 Taxman 692 (Mad.)(HC)

S. 14A : Disallowance of expenditure-Exempt income-Failure to examine the contention that no expenses were incurred to earn exempt income-Matter remanded. [S. 254(1), R.8D]

South Indian Bank Ltd v. CIT (2021) 438 ITR 1 / 205 DTR 337 / 322 CTR 465 / 283 Taxman 178(SC) Catholic Syrian Bank Ltd. v. CIT(2021) 438 ITR 1 / 205 DTR 33 / 322 CTR 465 (SC) Federal Bank Ltd. v. Dy. CIT (2021) 438 ITR 1 / 205 DTR 337 / 322 CTR 465 (SC)

S.14A : Disallowance of expenditure-Exempt income-Schedule bank-Stock in trade-Investment in shares and securities-Shares and securities are held as stock in trade-No disallowance can be made-Common funds-Non interest bearing funds more than the investment-There is no statutory provision which obligated the assessee to maintain separate accounts which might justify proportionate disallowance-Proportionate disallowance of expenses cannot be made. [R. 8D]

S. R. Trust v. PCIT (2021) 438 ITR 511 / 208 DTR 329/ 323 CTR 1051/( 2022) 285 Taxman 162 (Mad.)(HC)

S. 12AB : Procedure for fresh registration-Charitable Trust-Show cause notice for cancellation of registration-New procedure with effect from 1-4-2021-Application on 4-5-2021-Show cause notice dated 10-8-2021-Lack of jurisdiction-Writ is maintainable-Show cause notice was kept in abeyance till order passed on application as per new procedure. [S. 12A, Art, 226]

CIT (E) v. Batanagar Education and Research Trust (2021) 282 Taxman 1 (SC) Editorial : Batanagar Education and Research Trust v. CIT (E) (2021)129 Taxman.com 29 (Cal) (HC), set aside.

S. 12AA : Procedure for registration-Trust or institution-Survey-Donation received by way of cheque was returned to donors by cash-Cancellation registration and 80G exemption was held to be justified. [S.80G (v), 133A]