DIRECT TAXES - Supreme Courts

Madhur Agrawal, Niraj Sheth, Nishant Thakkar & Nitesh Joshi

1. Block Assessment – Computation of Undisclosed Income vis-a-vis set off of brought forward losses – S.158BB(4)

In view of expl. (a) to sec. 158 BB (4), it is mandatory that only brought forward losses of past year under chapter VI and unabsorbed depreciation u/s 32 (2) are to be excluded while aggregating total income or loss for the block period and set off of inter se losses and losses accruing in any previous year in the block period against the income assessed in other previous year in the block period is not prohibited E.K. Lingamurthy and Anr vs. Settl. Commissioner (2009) 222 CTR 1 (SC) (2009) 19 DTR 99 (2009) 178 Taxman 116 (SC)

2. Deduction – Hotel Business – S.80HH

The Supreme Court held that for the purpose of claiming deduction under section 80HH, the assessee has to demonstrate that it was a processer which has outsourced some of the activities to its sister concern. In the present facts where there are no details of the process undertaken by the assessee and the sister concern, the deduction under section 80HH would not be available.

CIT vs. R. Pratap (2009) 310 ITR 405 (SC)

3. Deduction of Tax at source – Jurisdiction – Assessee in default – Constitution of India – Article – S.2(47), 9(1)(1), 195, 201
The Supreme Court held that the question of jurisdictional issue may be determined by the authorities concerned as a preliminary issue. The supreme Court further held that the Petitioner would be entitled to question the decision of the authority on the preliminary issue before the High Court.

Vodafone International Holdings B.V. vs. Union of India (2009) 221 CTR 617 (SC)

4. Deduction of tax at source salary – S.192

The Supreme Court held that an employer is under no obligation to collect and examine the supporting evidence to a declaration submitted by an employee to the effect that he has actually utilised the amounts for the specified purposes in deciding the liability to TDS under section 192.

CIT vs. ITI Ltd. (2009) 221 CTR 619 (SC)

5. Depreciation when rule 8D applies – S.32

The Supreme Court held that in case of manufacturer of tea, by virtue of rule 8D, only 40% of the income is taxed and consequently in deciding liability only proportionate depreciation is required to be taken in to account as that is the depreciation actually allowed.

CIT vs. Doom Dooma India Ltd. (2009) 310 ITR 392 (SC)

6. Export – S.80HHC

The Supreme Court dismissed the appeal by the assessee from the decision of the High Court where it was held that where the reserve created for the purpose of special deduction under section 80HHC is of a lesser amount then deduction would be allowed only of the lesser amount supported by the creation of the reserve.

Prakash Brothers vs. CIT (2009) 309 ITR 446 (SC)

7. Interest – S.234A

The Supreme Court held even though the return of income is filed late, if the assessee has paid the taxes before the due date of the filing of the return which is not less then the tax payable on the returned income which has been accepted, no interest can be levied under section 234A.

CIT vs. Pranoy Roy (2009) 222 CTR 6 (SC)

8. Search & Seizure Surcharge – S.113

The Supreme Court held when the search was conducted on April 6, 2000, i.e. prior to June 1, 2002, the provisions of the Finance Act, 2001 would be applicable and surcharge would be leviable, on tax payable u/s. 113.

CIT vs. Rajiv Bhatara (2009) 310 ITR 105 (SC)

9. Tribunal-Enhancement – S.254(1)

The Supreme Court held that under section 254(1), the Tribunal has no power to take back the benefit conferred by assessing officer or enhance the assessment. In the present case since the assessing officer has granted depreciation the benefit could not be withdrawn by the Tribunal.

Mcorp Global P Ltd. vs. CIT (2009) 309 ITR

434 (SC)