DIRECT TAXES - Tribunal

Deepak R. shah, Haresh P. Shah, Paras S. Savla & Prem Chandra Tripathi

1. Additional Evidence – S. 144, Rule 46A

The Assessee had given all documents/ evidences to its counsel who failed to appear before the A.O. The A.O. proceeding to make an ex parte assessment u/s 144 by treating addition to unsecured loans and share application money as unexplained u/s 68. Before the CIT(A) the Assessee filed additional evidence u/r 46A and pleaded that it should not be made to suffer for no lapse on their part. The Tribunal held that CIT(A) was not justified in refusing to admit additional evidence.

Anmol Colours India (P) Ltd. vs. ITO, ITA No. 379/JP/2008, Bench – A, A. Y. 2002-03, dt. 20-6-2008 – BCAJ p. 24, Vol. 40-B, Part 1, October 2008.

2. Appeal – Binding – Precedent – S. 260A

Appeal dismissed holding that no substantial question of law arises amounts to affirmation of tribunals decision on merits which becomes binding on Tribunal.

Medicare Investments Ltd. vs. Jt. CIT (2008)114 ITD 34 (Delhi) (SB) / 304 ITR 44 (Delhi) (SB)(AT)

3. Appeal – S. 234B

When the chargeability of interest under section 234B itself is challenged the same is appealable.

ICICI Ltd. vs. Jt. CIT (2008) 119 TTJ 848 (Mum.)

4. Bad Debts – Business Laws – S. 28, 36

Irrecoverable brokerage due to the share broker was allowable as deduction on being written off as irrecoverable.

Angel Capital & Debt Market Ltd. vs. ACIT (2008) 118 TTJ 351 (Mum.)

5. Block Assessment – Time limit for completion of block assessment – S. 158BE

On the day of the search (i) panchnama prepared with the remark that ‘search temporarily concluded for the day to be commenced subsequently’; and (ii) prohibitory order u/s 132(3) issued. After a period, prohibitory order revoked and panchnama prepared with the remark ‘search is finally concluded’. Held that the period of limitation is to be computed from the date search was originally initiated and not from later date of panchnama.

Nandlal M. Gandhi vs. ACIT, IT(SS)A No. 11/Mum/2000, Bench – E, Block period 1-4-1987 to 28-7-1997, dt. 16-6-2008 (Third Member) – BCAJ pg. 270, Vol. 40-B, Part 2, November 2008/(2008) 13 DTR 35 (Mum.)

6. Book Profit – S. 115JB

Provision for warranty is an ascertained liability and it cannot be added while computing book profit under section 115JB

Sony India (P) Ltd. vs. DCIT (2008) 118 TTJ 865 (Del.)

7. Business Expenditure – Capital or Revenue – S. 37(1)

Training expenses incurred on personnel in relation to operation and maintenance of plant to be set up, was held to be capital expenses as training was given before plant was set up, though claimed during relevant previous year on ground that invoice was received during relevant previous year and TDS was deducted and paid in said year.

Gujarat Guardian Ltd. vs. JCIT (2008) 174 Taxman 151 (Del.)

8. Business Expenditure – S. 37(1)

Expenses on foreign tour by assessee as a trade delegate of Bengal National Chamber of Commerce and Industries (BNCCI), which was supported by a certificate issued by the BNCCI that he was a member of delegation which visited China to promote trade & business co-operation between India and China, was held to be an allowable as business expenditure.

It was further held that, for allowing expenditure of a foreign trip it is not necessary that it should result in introduction of new methodology or an increase in production must result because of foreign tour undertaken.

Ajit Kumar Ganguly vs. ACIT (2008) 175 Taxman 38 (Kol.)

Loss on foreign exchange fluctuation is not a notional loss and therefore, it is allowable as deduction.

Sony India (P) Ltd. vs. DCIT (2008) 118 TTJ 865 (Del.)

Provision for warranty is an ascertained liability and therefore it is allowable as deduction.

Sony India (P) Ltd. vs. DCIT (2008) 118 TTJ 865 (Del.)

Payment for accessing National Stock Exchange for controlling trading functions was for business purpose and allowable as business expenditure.

Angel Capital & Debt Market Ltd. vs. ACIT (2008) 118 TTJ 351 (Mum.)

Ad hoc disallowance of 10% out of commission payment to foreign agents, without pointing out any discrepancy, and which was remitted after RBI clearance, was held to be unjustified.

Malwa Industries Ltd. vs. ACIT (2008) 175 Taxman 40 (Chandigarh)

9. Business Income – Income from house property – Ss. 22, 28

Income earned by a company from leasing information technology park, constructed by it on land belonging to the company (which land was initially taken on lease and was later on acquired) which construction was financed by borrowings from banks secured on immovable property of the company, and providing various amenities and services is chargeable to tax under the head ‘Business income’ and not ‘Income from house property’.

Global Teck Park Pvt. Ltd. vs. ACIT, ITA No. 1021/Bang/2007, A.Y. 2003-04, dt. 30-6-2008 – BCAJ p. 392, Vol. 40-B, Part 3, December 2008.

10. Cash Credit – S. 68

Assessee disclosed the sale of shares and receipt thereof in her Return of Income and claimed exemption u/s 54EC, but could not produce broker and purchaser and even requisition u/s 133 (6) were returned unserved. Assessing Officer treated the sale proceeds of shares as her unexplained cash credits u/s 68.

Held, that as the transaction entered was duly supported by Bill, Contract Note, Delivery and transactions having been reflected in Balance Sheets, and Assessing Officer having no evidence, additions based merely on doubts can not be justified.

Km. Saumya Agrawal vs. ITO (2008) 173 Taxman 60 (Agra)

11. Charitable Trust – Registration – S. 12A(a)

The Assessee society registered on 1-9-2005. The Assessee applied for registration on 10-4-2007 before the CIT who granted registration vide order dt. 7-11-2007 w.e.f. 1-4-2007. The Tribunal held that once the CIT is satisfied about objects the trust and genuineness of activities, he is required to grant registration w.e.f. 1-9-2005.

Note : Section 12AA has been amended w.e.f. 1-6-2007

The Indus Entrepreneur vs. The CIT – II, ITA No. 32/JP/2008, Bench – B, A.Y. 2003-4, dt. 20-6-2008 – BCAJ p. 26, Vol. 40-B, Part 1, October 2008.

12. Deduction – Prepaid Lease Rent – S. 37

Prepaid lease rental which is pertaining to the next financial year/s is not allowable in the year of payment.

Dy. CIT vs. FAG Bearings India Ltd. (2008) 115 ITD 53 (Ahd.)(SB) / 306 ITR 60 (AT)

13. Deduction – S. 36(1)(iii)

Assessee a Banking Company, though indulging in different types of business of advancing loans including long term finances, can not per se be treated as financial institution, for purpose of availing special deduction u/s 36(1) (viii). Further, also as the notification for being recognized as financial corporation was not with assessee bank, the deduction can not be availed.

ACIT vs. Federal Bank Ltd. (2008) 175 Taxman 102 (Coch.)

14. Deduction – S. 80RR

The denial of deduction u/s 80RR for remuneration received for doing consultancy work, was not justified, on ground that Assessee was neither an author, playwright, artist, musician or actor or a sportsman.

Held, Income derived by an Individual relating to his professional activities, and being derived in exercise of his profession is eligible for deduction u/s 80RR.

Brahma Dev Sharma vs. ACIT (2008) 174 Taxman 62 (Del.)

15. Deduction – S. 80-IA r.w.s 80HHC

Deduction allowed u/s 80-IA is not to be reduced from the profits of the business in computing the deduction u/s 80HHC

J. B. Chemicals & Pharmaceuticals Ltd. vs. ACIT, ITA No. 6044/Mum/2002, Bench – B, A.Y. 1999 – 2000, dt. 30-7-2008– BCAJ p. 271, Vol. 40-B, Part 2, November 2008.

16. Deduction – S. 80-IB

Benefit of deduction u/s 80-IB, cannot be allowed on interest income and miscellaneous income surrendered during survey u/s 133A, as no nexus had been established by assessee that same has been derived from an industrial undertaking.

DCIT vs. Shiva Fabricators (P) Ltd. (2008) 174 Taxman 155 (Chandigarh)

17. Depreciation – Stock Exchange Membership Card – S. 32

Stock exchange membership card acquired after 1-4-1998 represents a commercial right/intangible asset and therefore qualifies for depreciation u/s 32.

K. Damani Securities Pvt. Ltd. vs. ITO, ITA No. 2568/Mum/2004, A.Y. 2001-02, dt. 22-10-2007– BCAJ p. 273, Vol. 40-B, Part 2, November 2008.

18. Depreciation – Ss. 32, 43(1)

Vehicle was purchased by HUF of Assessee, and on which no Depreciation was claimed, nor, same was used for purpose of business. The vehicle was brought as business asset of Assessee in his individual capacity after 3 years at original cost.

Assessing Officer invoked provisions of the explanation to section 43(1), and reduced the original cost of Rs. 3,86,607/- to Rs. 2,00,000/-, and computed depreciation accordingly. Held, that as statute does not give discretion for purpose of the Explanations 3 to S. 43(1) to enforce Depreciation, as two of the prescribed conditions needs to be fulfilled to justify and substitute the cost of WDV as claimed by the Assessee, and accordingly, Assessee was entitled to depreciation on original cost of vehicle as claimed.

Shashikant Janardan Kulkarni vs. ITO (2008) 173 Taxman 116 (Pune)

19. Disallowance – S. 40A(2)

Once it is decided that services have been rendered by an agent, then quantum of Commission to be paid is purely at discretion of assessee, and revenue cannot sit in judgment over same, and restrict the claim by reducing the % of commission, as being excessive or un-reasonable.

Gujarat Guardian Ltd. vs. JCIT (2008) 174 Taxman 151 (Del.)

20. Educational Institutions – S. 10(23C)(vi)

The eligibility of exemption u/s 10(23C) has to be determined with reference to the objects of the institution. Further, exemption cannot be denied if there results some surplus after meeting the expenditure incurred towards the activities, to attain the objects.

Arvind Bhartiya Vidyalaya Samiti vs. ACIT (2008) 173 Taxman 119 (Jai.)

21. Expenditure – S. 37

Amount spent on the prizes given under the lottery system allowed as business expenditure.

Eyetech Industries vs. ACIT, ITA No. 1799/Mum/2005, A.Y. 2001-02, dt. 31-7-2008 – BCAJ pg. 273, Vol. 40-B, Part 2, November 2008.
22. Expenditure – S. 37(1)

Interest free loan to a relative of a partner for purchase of flat which was used for the purpose of business of the assessee cannot be disallowed.

DCIT vs. Parthas Power House, ITA No.50 & 51/Cochin/2007, A.Ys. 2003-04 & 2004-05, dt. 12-6-2008– BCAJ p. 272, Vol. 40-B, Part 2, November 2008.

23. Expenditure in relation to exempt income – Disallowance – S. 14A

Section 14A applies to all heads of income which disallows expenditure incurred in relation to income not forming part of total income.
ITO vs. Daga Capital Management (P) Ltd. (2008) 119 TTJ 289 (SB) (Mum.)

24. Export – Difference in foreign exchange receipt – S. 80HHC

Sale proceeds of export received in subsequent year or after end of year, then the difference in foreign exchange rate – gains to be included in the turnover of the relevant year of export and not in the year of such receipt.

ACIT vs. Prakash L. Shah (2008) 306 ITR 1 (Mum.)(SB)(AT)

25. Housing Project – Deduction – S. 80-IB(10)

The Assessee purchased land in 1996 and wall was constructed. Original plan expired after validity period of one year. Revised plan was approved and commencement certificate issued on 30-9-2000. User of land for non-agricultural purposes was permitted on 28-6-2001. The A.O. disallowed the claim for deduction u/s 80-IB(10) on the ground that the condition i.e. commencement of the construction after 1-10-1998 was not satisfied. The Tribunal held that expenses incurred for change of land use and other administrative/ other land development expenses incurred prior to statutory approvals, which have been received after 1-10-1998 cannot result into commencement of the project before 01-10-1998, Hence, deduction u/s 80-IB allowed.

ITO. vs. Shri Vimalchand M. Dhoka, ITA Nos. 5520/Mum/2005, Bench – ‘A’, A. Y. 2002-03, dt.19-5-2008 - BCAJ p. 23, Vol. 40-B, Part 1, October 2008.

26. Income – Waiver of loan – S. 2(24)

Waiver of loan obtained and utilized for purchasing any capital assets is not taxable as it is a capital receipt.

Fidelety Textiles P. Ltd vs. ACIT (2008) 305 ITR 97 (Chennai)(TM)(AT)

27. Interest – Ss. 14A, 36(1)(iii)

Dividend Income earned which was exempt u/s 10(33) by the Assessee company carrying on business of dealing in shares and securities, is incidental to its business activity, and, action of Assessing Officer disallowing proportionate interest paid on the investments made out of borrowed funds invoking provisions of section 14A was held not justified.

It was further held that entire expense is allowable u/s 36(1) (iii), as borrowed funds were utilized for purchase of shares which were kept as stock-in-trade.

Pankaj Piyush Trade & Investment Ltd. vs. ACIT (Mum.) – 174 Taxman 93

28. Interest – Ss. 234A, 234B

As the interest income on compensation / enhanced compensation would be taxable only when dispute pertaining to acquisition of land is finally settled, the levy of interest u/ss. 234A and 234B cannot be justified, prior to settlement of dispute as Assessee was neither liable to file Return nor was required to pay advance tax in the year which it belonged but settled subsequently.

ITO vs. Smt. Sarbati Devi (2008) 174 Taxman 124 (Del.)

29. Interest on Borrowed Capital – Ss. 2(28A), 36(1)(iii)

Pre-payment premium, being interest paid on moneys borrowed for business purpose and allowable as revenue expenses is deductible in year of accrual thereof, as the Act does not recognize concept of deferred expenditure. Thus action of Assessing Officer allowing deduction of one-tenth holding same as capital in nature was held as not justified.

Gujarat Guardian Ltd. vs. JCIT (2008) 174 Taxman 151 (Del.)

30. Interest on Borrowed Capital – S. 36(1)(iii)

Assessee made advances to related parties for business considerations and business expediency. No proportionate interest paid by assessee on borrowed capital can be disallowed.

Yamaha Motor India (P) Ltd. vs. ACIT (2008) 118 TTJ 395 (Del.)

31. Loss – Return – Ss. 74, 80, 139

Assessee is entitled for claim of carry forward of Capital Loss made in the Revised Return filed within time prescribed u/s 139 (5), on realization of mistake, made in Original Return, which too was filed within time allowed u/s 139(1).

Sat Pal Sachdeva vs. ACIT (2008) 174 Taxman 157 (Chandigarh)

32. Manufacture – S. 80-IB

Business of the assessee, which is producing masala of different varieties, is manufacture of goods or is processing of goods and hence deduction u/s 80-IB is to be allowed.

ACIT vs. Empire Spices & Foods Mumbai Ltd., ITA No. 4477/Mum/2006, A.Y. 2003-04, dt. 18-9-2008 – BCAJ p. 391, Vol. 40-B, Part 3, December 2008.

33. Mistake – Appeal on Record – S. 254

When the fact of pendency of Departmental appeal was not pointed out at the time of hearing of the appeal of the assessee, it cannot be said that the Tribunal has committed an error while hearing only the assessee’s appeal.

ACIT vs. Changepond Technologies Pvt. Ltd., M.P. No. 137/Mds/08, A.Y. 03 – 04, dt. 14-8-2008 – BCAJ p. 394, Vol. 40-B, Part 3, December 2008.

34. New Industrial Undertaking – S. 80-I, 80HHA

Process of standardization and pasteurization of milk does not amount to manufacture / production for purpose of claiming deduction under section 80-I and 80 HHA.

B. G. Chitale vs. Dy. CIT (2008) 115 ITD 97 (Pune)(SB) / 305 ITR 81 (Pune)(AT)

35. Outstanding unsecured loan for more than ten years – S. 41(1)

Unsecured loan not being any trading transaction neither written off nor transferred to Profit & Loss and remained outstanding for more than 10 years could not be brought to tax under the provisions of section 41(1) of the Act.

Inderson Leathers (P) Ltd. vs. Addl. CIT (2008) 114 ITD 242 (Asr.)

36. Penalty – S. 271(1)(c)

Concealment penalty can not be composed only on ground that some additions had been made in the Assessment which were subsequently, confirmed in Appeal. Further, it was held that though findings given in Assessment is a good evidence, same is not conclusive in penalty proceedings. For penalty, it has to be seen that additions made are based on material from which an inference can be drawn that Assessee has concealed Income

ITO vs. Ravi Khurana (2008) 173 Taxman 26 (Delhi)

A) The denial of deduction by cancelling the assessment, by Commissioner acting u/s 263 pursuant to subsequent judgment of the Supreme Court would not constitute concealment or furnishing of inaccurate particulars.

B) Imposition of penalty u/s 271(1) (c) on expenses of foreign travel of Directors disallowed by A.O and upheld by Tribunal for non business consideration, without holding that claim for expenses reflected any falsity or lacking in bonafide was held to be not justified as it was merely difference of opinion as regards allowability of claim.

ACIT vs. Vijay Kiran Hotels (P) Ltd (2008) 175 Taxman 126 (Chandigarh)

37. Profits derived from Industrial undertaking – Ss. 10A & 10B

Foreign exchange gain is includible in the profits eligible for deduction under sections 10A & 10B.

Sony India (P) Ltd. vs. DCIT (2008) 118 TTJ 865 (Del.)

38. Reassessment – Reason to believe – S. 148

No reopening is permissible merely on the ground that Balance Sheet revealed some NRI gifts and where there was no investigation or any evidence having any live link or nexus with the reason to believe that there was escapement of income. Reopening on such facts is void ab initio and bad-in-law.

ACIT vs. O. P. Chawala (2008) 114 ITD 69 (Delhi) (TM) / 306 ITR 328 (Delhi) (TM) (AT)

39. Reassessment – Service of Notice – S. 148

A. O. could not have assumed any jurisdiction to complete assessment / reassessment unless legal and valid notice in accordance with the provisions of law was issued and served. Mere participation in the reassessment proceedings cannot be validated the reassessment proceedings.

Anil Kumar Goel vs. ITO (2008) 115 ITD 245 (Luck.)

40. Remission of liability or cessation of trading liability – S. 41(1)

Remission or cessation of liability on account of waiver of loan which was not claimed as deduction in any year cannot be brought to tax u/s. 41(1) in any year.

Coastal Corpn. Ltd. vs. Jt. CIT (2008) 307 ITR 78 (Visakhapatnam) (AT)

41. Re-opening – S. 147

Assessee HUF filed Return without disclosing Capital Gain arising on sale of an agricultural land. However, Assessee disclosed the same by way of Note, below the Capital Account, stating that Capital Gain is not taxable, as deduction u/s 54B is available on Gain being investment in another agricultural land, Return was originally accepted

u/s 143(1)(a), and later same was re-opened u/s 148 on ground that Capital Gain is not included in the Return of Income. Held, that as original assessment was completed u/s 143(1)(a), no opinion was formed therein, and it can not be said that reassessment was on basis of change of opinion, and thus re-opening was justified.

Section 54 B : It was held that deduction u/s 54 B is available to all the Assessee. The word “Assessee” is not qualified by any class of Assessee and HUF is eligible for deduction u/s 54 B.

K. S. Jain & Sons (HUF) vs. ITO (2008) 173 Taxman 114 (Del.)

42. Search & Seizure – Jurisdiction – Ss. 132A, 158BC

Jurisdiction to complete assessment u/s. 158BC is conferred on the concerned A.O. only on physically handing over all the relevant books of account/documents or assets requisitioned u/s. 132A of the Act.

ACIT vs. Sonu Verma (2008) 115 ITD 37 (Asr.)(SB) / 305 ITR 406 (Asr.)(SB)(AT)

43. Speculation transactions – S. 43(5)

The loss suffered in F & O transactions could not be considered as speculation loss under section 43(5).

R.B.K. Securities Ltd. vs. ITO, ITA No. 2465/Mum/2006, Bench – B, A.Y. 2003-04, dt. 21-7-2008 – BCAJ p. 27, Vol. 40-B, Part 1, October 2008.

44. TDS – Credit for Tax Deducted when income not assessable in relevant A.Y. – S. 199

Credit for Tax Deducted at Source, if income is not assessable in relevant assessment year, shall be allowed on pro-rata basis; i.e., in proportion in which such income is offered for taxation in different assessment years.

Pradeep Kumar Dhir vs. ACIT (2008) 303 ITR 45 (Chand.) (TM)(AT)

45. TDS – Credit for Tax Deducted when no TDS certificate is furnished by employer – S. 199

In such case TDS could not be recovered from assessee in view of section 205 of the Income-tax Act.

Capt . J. G. Joseph vs. Jt. CIT (2008) 303 ITR 395 (Mum.)(AT)

46. Transfer Pricing – S. 92C

Transfer pricing provisions are to prevent shifting of profits outside India and the assessee is claiming benefits under section 10A. The transfer pricing provisions ought not to be applied to the assessee.

Philips Software Centre (P) Ltd. vs. ACIT (2008) 119 TTJ 721 (Bang.)

47. Tribunal – Power – S. 254

Tribunal has no jurisdiction to examine validity of the order for appointment of special auditor under section 142(2A) in the course of appeal before it.

ACIT vs. Badri Ram Choudhary (2008) 118 TTJ 492 (Jd.)

48. Unexplained Investment – S. 69

Assessee’s Income cannot be assessed on basis of statement of a third party, unless there is a material to corroborate that statement. Burden shifts on the revenue to prove that Assessee had deliberately suppressed his Income.

ITO vs. Dr. R. L. Narang (2008) 174 Taxman 96 (Chand.)