Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


L.K.P.Merchant Financing Ltd v .Dy.CIT ( 2022) 447 ITR 507 / 288 Taxman 389 / 329 CTR 909/ 220 DTR 231( Bom)(HC) www.itatonline .org .

S. 36(1)(vii) :Bad debt – Pendency of dispute – Lease rental – Depreciation -Once a business decision has taken to write off a debt as a bad debt in books of account should sufficient to allow the claim as bad debt [ S. 36(2) ]

PCIT v. Sreeleathers (2022) 448 ITR 332/ 143 taxmann.com 435 ( Cal)( HC) www.itatonline .org

S. 68 : Cash credits –lenders are assessed to tax- Confirmation was filed – Interest was paid ,TDS was deducted – Notice issued u/s 133(6) were acknowledged – Order of Tribunal deletion of addition was affirmed – Court observed that the Assessing officer should have desisted from using the general observation and expression “money Laundering” when it was never the case that there was any allegations of money laundering . [ S. 133(6) ]

Nasiruddin v. ITO (2022) 444 ITR 318 (Karn.)(HC) Fatima v. ITO (2022) 444 ITR 318 (Karn.)(HC) Raheesahmed v. ITO (2022) 444 ITR 318 (Karn.)(HC)

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Assessee must be given opportunity to compound offence. [S. 139, 279, Art, 226]

K. E. Gnanavel Raja v. ACIT (2022) 444 ITR 562 / 287 Taxman 127 (Mad.)(HC)

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Mens rea must be proved-Penalty Levied and paid for furnishing incorrect particulars in Income-Tax Return-Prosecution was not valid. [S. 132(4)(a), 277]

Zeal Real Estate Ltd. v. UOI (2022) 444 ITR 442 (Bom.)(HC)

S. 269UD : Purchase by Central Government of immoveable properties-Notice must give details which led to inference of undervaluation-Order pf Pre-Emptive purchase not valid-Transferee has a right to challenge order of purchase. [Art, 226]

Ashwika Kapur v. UIO (2022) 444 ITR 241 (Cal.)(HC)

S. 269UD : Purchase by Central Government of immoveable properties-Valuation of property should be just and reasonable-Rent capitalisation method-Adequate opportunity to be heard not given-Order of purchase of property-Not valid. [Form No. 37I, Art, 226]

Unisource Hydro Carbon Services Pvt. Ltd. v. UOI (2022) 444 ITR 229/(2023) 334 CTR 95/ 226 DTR 164 (Cal.)(HC) Editorial : Order of single judge Unisource Hydro Carbon Services Pvt. Ltd. v. UOI(2022) 444 ITR 227 (Cal) reversed.

S. 264 : Commissioner-Revision of other orders-Order of dismissal by Single judge is held to be not proper-Order of Principal Commissioner set aside-Matter remanded to Principal Commissioner. [S. 143(3), 246A, Art, 226]

KLJ Organic Ltd. v. CIT (IT) (2022) 444 ITR 62 / 286 Taxman 282 (Delhi)(HC)

S. 264 : Commissioner-Revision of other orders-Limitation-Pursuing appeal mistakenly-Delay in filing revision petition-Period spent in prosecuting appeal excluded-Matter remanded to Commissioner. [S. 246A, 248, Limitation Act, 1963, S. 14, Art, 226]

Mallelil Industries Pvt. Ltd. v. ITO (2022) 444 ITR 80 / 288 Taxman 303 / 213 DTR 387/ 326 CTR 625(Ker.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Penalty-Concealment-Commissioner setting aside entire Assessment-Assessing Officer acting under such order of remand can initiate penalty proceedings. [S. 143(3), 271 (1)(c), Art, 226]

PCIT v. Rashmi Metaliks Ltd. (2022) 444 ITR 75/ 215 DTR 260 / 327 CTR 328(Cal.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Deduction could not be denied on ground companies which used Railway Sidings were group companies-Revision is not valid. [S. 80IA(4)(i)(b)]