Reported  Judicial Decisions - Direct Tax

Reported Judicial Decisions - Direct Tax

Statute: Income Tax Act 
Sec.10(4)(ii) – Interest on NRE account    
Decision in favour of : Revenue
Title  : Baba Shankar Rajesh  vs  ACIT
Citation: 180 ITD 160    
Bench: ITAT Chennai

Where assesse who was a non-resident earlier, stayed in India for relevant financial year for 283 days for taking up employment, he would become resident in India as per FEMA: thus he would not be entitled to exemption u/s 10(4)(ii) on the interest in his NRE deposits 

Statute: Income Tax Act
Sec.11 – Facilities hired from corporates    
Decision in favour of : Assessee
Title  : Devki Devi Foundation   vs  DIT (E)
Citation: 180 ITD 417    
Bench: ITAT Delhi

Charitable trust having retained control and supervision of hospital run by it, entering into agreement for availing services of corporates for running hospital does not disentitle from exemption under section 11 or face cancellation under 12AA(3)

Statute: Income Tax Act
Sec.40b – Allowable when profit estimated
Decision in favour of : Assessee
Title  : Mayasheel Construction  vs  DCIT
Citation: 77 ITR Trib SN 8    
Bench: ITAT Delhi

Interest and remuneration to working partners is allowable as deduction even after estimation of net profit of the frim as a percentage of gross receipts 

Statute: Income Tax Act
Sec.46A – Capital gain on buy back    
Decision in favour of : Revenue
Title  : Acciona Wind Energy Private Ltd  vs  DCIT
Citation: 185 DTR Trib 280    
Bench: ITAT Bangalore
 
Section 45 and 46A operate in different fields. Sec.45 is applicable regarding transfer of a capital asset whereas section 46A is applicable in respect of consideration from any company for purchase of its own shares. Since there is no requirement in section 46A that there has to be a transfer of shares, section 47(iv) is not applicable in connection with the issue covered by section 46A. Further the there are two shareholders in the company, one being its parent and the other another associate concern and such associate concern is not holding the share as nominee of parent company and hence the claim that it is a wholly owned subsidiary is not acceptable.

Statute: Income Tax Act
Sec.73 – No distinction for delivery based     
Decision in favour of : Assessee
Title  : Lohia Securities Ltd  vs  DCIT
Citation: 180 ITD 1 TM        
Bench: ITAT Kolkatta

Where assesse , a sharing broking company, treated entire activity of purchase and sale of shares, which comprised of both delivery based and non-delivery based trading as one composite business and accordingly claimed set of loss incurred in delivery based trading against profit derived from derivative trading, same was to be allowed 

Statute: Income Tax Act
Sec.80G(5) – Approval cannot be denied     
Decision in favour of : Assessee
Title  : Sabtera Foundation  vs  CIT (E )
Citation: 77 ITR Trib 296        
Bench: ITAT Chandigarh

Approval cannot be denied only for the reason that the trust was formed by another company for complying with the CSR requirements especially because registration u/s 12A was already granted  and no doubt raised about charitable objects of the assesse or fulfillment of conditions for 80G approval 

Statute: Income Tax Act
Sec.143(2) – Notice by affixture     
Decision in favour of : Assessee
Title  : Tourism India Management Enterprises Private Ltd  vs  DCIT
Citation: 77 ITR Trib 311        
Bench: ITAT Delhi

Notice by way of affixation was only to be served when the correct address was not available or the assesse had refused to accept the service of notice. Since notice was never issued to the correct address, affixation will not be valid and consequently assessment framed u/s 143(3) was void ab initio 

Statute: Income Tax Act
Sec.194 H – Credit card commission 
Decision in favour of : Assessee
Title  : PCIT  vs  Hotel Leela Venture Ltd
Citation: 420 IR 385         
Bench: Bombay HC

Charges collected by bank for providing credit card services at the establishment did not amount of commission warranting TDS under section 194 H. No disallowance attracted 

Statute: Income Tax Act
Sec.194 I – Lounge services at airport     
Decision in favour of : Assessee
Title  : CIT  vs  Jet Airways India Ltd
Citation: 420 ITR 399        
Bench: Bombay HC

Payment made by airline company for use of airport lounge facilities by its customers while in transit does not fall within the meaning of rent attracting TDS under section 194 I since such premises was not in the exclusive usage of the assesse or its customers . However the same could fall under the section 194 C which the assesse has complied with 

Statute: Income Tax Act
Sec.251(1)(a) – CIT(A) has to dispose appeal on merits only     
Decision in favour of : Asseessee
Title  : Deekay Gears   vs ACIT
Citation: 77 ITR Trib 150        
Bench: ITAT Mumbai

Even when the assesse has filed application for withdrawal of appeal, CIT(A) has to consider the appeal and dispose on merits. CIT(A) not justified in dismissing appeal in limine based on assesse application 

Statute: Income Tax Act
Sec.263 – Failure to convert limited scrutiny    
Decision in favour of : Revenue
Title  : Baby Memorial Hospital Ltd  vs  ACIT
Citation: 77 ITR Trib Coch 484         
Bench: ITAT Cochin

Even in cases of limited scrutiny, AO is duty bound to make prima facie enquiry as to whether there is any other item which requires examination and in the assessment, the potential escapement of income thereof exceeded Rs.10 lakhs.  AO having failed to convert limited  scrutiny into a complete scrutiny, is an erroneous order calling for revision under section 263.

Statute: Income Tax Act 
Sec.271(1)(c ) – Income declared in survey    
Decision in favour of : Assessee
Title  : PCIT  vs  Shree sai Developers
Citation: 186 DTR 105        
Bench: Gujarat HC

Assessee having declared undisclosed income during survey filed return including such and said return accepted by AO in assessment u/s 143(3), there is no filing of inaccurate particulars attracting penalty

Statute: Income Tax Act
Sec.271G – No penalty when no specific defect     
Decision in favour of : Assessee
Title  : Procter & Gamble Home Products (P) Ltd   vs  DCIT
Citation: 180 ITD 194        
Bench: ITATMumbai

TPO levy of penalty stating that sufficient documents prescribed under rule 10D was not maintained by the assesse but the notice did not mention any specific document / record which was not maintained.  Unless and until a specific defect is pointed out in the documents, penalty could not be levied 

Statute: Income Tax Act 
Sec.276C,277-No action when quantum of penalty is reduced     
Decision in favour of : Assessee
Title  : K M Mammen  vs  DGIT
Citation: 186 DTR 78        
Bench: Madras HC

Once penalty for concealment stood reduced by CIT(A), section 279(1A) applied and prosecution under 276 C and 277 could not be launched.

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