S. 68 : Cash credits-Sale of agricultural land-Cash deposited in the bank account-Source of deposit explained-Addition is deleted-Re assessment is quashed. [S. 69,147, 148]
Jagir Singh v. Asst. CIT (2023)106 ITR 233/225 TTJ 462 (Chd) (Trib)S. 68 : Cash credits-Sale of agricultural land-Cash deposited in the bank account-Source of deposit explained-Addition is deleted-Re assessment is quashed. [S. 69,147, 148]
Jagir Singh v. Asst. CIT (2023)106 ITR 233/225 TTJ 462 (Chd) (Trib)S. 68 : Cash credits-Share Capital-Furnished bank statements, audited accounts and computations of income-Companies’ cases subjected to scrutiny assessment-Source of source explained-Shareholders and directors of companies not attending in response to summons-Not ground to tax credits. [S. 131]
Dy. CIT v. Narsingh Ispat Ltd. (2023)106 ITR 453 / 156 taxmann.com 344 (Kol) (Trib) Editorial : Affirmed in PCIT v. Narsingh Ispat Ltd [2024] 161 taxmann.com 483 / 463 ITR 566 (Cal)(HC)S. 57 : Income from other sources-Deductions-Interest paid on unsecured loans taken from family members Claimed Against interest earned on fixed deposits with banks-Matter remanded. [S. 40A(2)(b), 56]
D. D. and Co. v. Asst. CIT (2023)106 ITR 89 (SN)(Mum) (Trib)S. 57 : Income from other sources-Deductions-External commercial borrowings advanced as loans to sister concerns-Interest expenditure directly related to interest earned-Violation of Reserve Bank of India guidelines not relevant for allowance of deduction-Deduction is allowable .[ S. 56 , 57(iii) ]
Airmid Developers Ltd. v Dy. CIT (2023)106 ITR 82 (SN)(Mum) (Trib)S. 54F : Capital gains-Investment in a residential house-Investment of net consideration in construction of house-Full value of consideration-Deeming fiction is not applicable-Entitled to exemption-Penalty deleted. [S. 48, 50C, 139(4), 271(1)(c)]
Lalit Kumar Kalwar v. ITO (2023)106 ITR 373 /226 TTJ 192 / 156 taxmann.com 27 (SMC) (Jaipur) (Trib) Lalit Kumar Kalwar v. ITO (2023)106 ITR 401 (Jaipur) (Trib)S. 54B : Capital gains-Land used for agricultural purposes-Finding that land not used for agricultural purposes in two preceding years No agricultural is shown by assessee in past years-Order of Assessing Officer is affirmed. [S. 45]
Dy. CIT v. Subhash Hastimal Lodha (2023)106 ITR 101 (SN) /(2024) 228 TTJ 492 (Pune)(Trib)S. 50C : Capital gains-Full value of consideration-Stamp valuation Amendment providing for adoption of value as on date of agreement is retrospective . As Amended By Finance Act, 2016.
Anupama Krishna Rao Premaraju (Smt.) v. ITO(IT) (2023) 106 ITR 97 (SN.) / 156 taxmann.com 32 (Hyd) (Trib)S. 48: Capital gains-Mode of Computation-Long-term capital gains-Full value of consideration-Listed Shares held as investment-Off-market sale under share purchase agreement at price prevailing on date of share purchase agreement-Adoption.
Trak Services P. Ltd. v ITO (2023)106 ITR 58 (SN)/ 226 TTJ 249/ 156 taxmann.com 226 (Delhi)(Trib)S. 44BB : Mineral oils-Computation-Non-Resident-Royalty-Charter of Vessel with crew for mineral oil extraction-Revenue earned from charter hire charges not royalty-Receipts of reimbursement intricately linked to chartering income-Not taxable-DTAA-India-Singapore. [S. 9(1)(vi), Art. 8(4)(b), 8(4)(c)]
Smit Singapore Pte. Ltd. v .Dy. CIT (IT) (2023)106 ITR 490 / 151 taxmann.com 197 (Mum) (Trib)S. 44BB : Mineral oils-Computation-Presumptive tax-Non-resident having Permanent Establishment in India-Income from contracts for processing of marine seismic data, seismic data acquisition and processing, hiring of vessel and technology-Taxable on presumptive basis-Advance tax-Non-resident not chargeable with interest. [ S. 9(1)(vii) , 44DA, 234B ]
Western Geco International Ltd. v. Dy. CIT(IT) (2023)106 ITR 134/ 157 taxmann.com 736 (TM) (Delhi) (Trib) Pacific Crest Pte. Ltd. v Dy. CIT (IT) (2023) 201 ITD 11/ 106 ITR 312 / 149 taxmann.com 85 (Delhi) (Trib)