DIRECT TAXES - Tribunal

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

1. Accounts – Investment or stock-in-trade – S. 145

The Assessee holding shares both as investment and stock in trade. As per the A.O., the assessee who belong to the promoter group of Premier Automobiles, would be holding the shares with sole motive of retaining the control and hence cannot be recognised as stock in trade. Held that method of valuation of stock was one consistently followed and accepted.

ACIT vs. Pal Enterprises Pvt. Ltd., ITA Nos. 1994/Mum/2005, Bench – ‘H’, A. Y. 01 – 02, dt. 20-10-2008 – BCAJ p. 518, Vol. 40-B, Part 4, January 2009.

2. Accounts – Method of accounting – S. 145

The Assessee is having more than one source of income under the head ‘Business income’. Held that the Assessee has option to follow different methods of accounting in respect of each of different sources of income under the head.

ACIT vs. Mehul J. Somaiya, ITA No. 7118/Mum/2007, Bench – B, A.Y. 2002 – 03, dt. 10-12-2008 – BCAJ p. 670, Vol. 40-B, Part 5, February 2009.

3. Amortisation of Expenses – S. 35D

Fees paid to Registrar of Companies for increasing share capital falls within the ambit of S. 35D and allowable as deduction.

ACIT vs. Fascel Ltd. (2009) 120 TTJ 289 (Delhi)

4. Appelate Tribunal – Right of Respondent – Rule 27 of ITAT Rules

The respondent can support his argument against the appeal filed by the Appellant on the points which has been rejected by the CIT (A).

Dy. CIT vs. Hind Industries Ltd. (2009) 120 TTJ 505 (Delhi)

5. Best Judgment Assessment – S. 144

Held, that Best Judgment Assessment on basis of conclusion based on suspicion and false notions and assumption, as per Assessing Officer’s own whims and yardsticks, is not justified.

Further it was observed that :

i) Best Judgment Assessment has to be fair, reasonable and based on material, wherein some guess work cannot be ruled out.
ii) Once books of account is rejected, then reliance on some entries in those books to make separate addition is not justified.

ACIT vs. Smt. Renu Mukerjee – 177 Taxman 58 (Delhi)

6. Block Assessment – Satisfaction – S. 158BD

In view of the fact that there was a delay of more than 19 months in issuance of notice u/s 158BD of the Act after the completion of the assessment order in the case of the person searched and also because the satisfaction required u/s 158BD of the Act was not recorded by the Assessing Officer of the person searched, the proceedings are vitiated and need to be declared as null and void.

Bharat Bhushan Jain vs. ACIT, IT(SS)A No.13/Del/2007, Bench – A, A.Y. 1991-92 to A.Y. 01-02, Dt. 7-11-2008 - BCAJ pg. 794, Vol. 40-B, Part 6, March 2009.

7. Business Expenditure – Development of website – S. 37(1)

Business expenses incurred for development of website to promote business activities, and display information and products is allowable as Revenue Expenditure Polyplex Corp. Ltd. vs. ITO – 176 Taxman 57 (Delhi)

8. Business Expenditure – Donation – S. 37

Deduction in respect of donation to a charitable trust with a specific direction that the amount should be treated as corpus and it should be invested in a manner that interest earned on the investment would be utilized for purpose of purchase of books and magazines and to provide other library facilities to practising advocates.

But it was, on the facts and circumstances, held that such expenditure could not be allowed for the reasons that, the assessee could not bring any evidence or material on record to prove as to what business purpose was served in the business by making such donation and no commercial expediency was established.

A. N. Mathur vs. Dy. CIT (2009) 117 ITD 274 (Indore).

9. Business Expenditure – Interest prior period – Ss. 37 (1), 145

Assessee company engaged in business of land development paid interest as per resolution Dt. 8-9-2002 in the year of non-materialisation of terms of Agreement Dt. 13-6-1997. Held Assessing Officer’s action denying deduction of interest as prior period expenses was not justified, and Assessee’s claim was admissible u/s 145, as the claim of deduction of Interest had actually accrued / capitalised and ascertained in the year under consideration on non-materialisation of terms viz. approval being rejected.
Urban Improvement Co. (P) Ltd. vs. ITO (2009) – 177 Taxman 104 (Delhi)

10. Business Expenditure – Luxury Tax – S. 37

Payments made towards luxary tax and not penalty, is allowable as deduction.

RDB Industries Ltd. vs. Dy. CIT (2009) 120 TTJ 107 (Kol.)

11. Business Expenditure – Prior period expenses – S. 145

During the year the Assessee cancelled the MOU and refunded the amounts received under MOU along with interest as per the terms of the MOU. The Assessing Officer disallowed the interest paid for the period covering earlier years on the ground that it was prior period expense. Held that the liability to pay interest had accrued in the year under consideration when the resolution was passed and not prior to that. The liability under consideration was contractual liability and was crystallised and ascertained only when the decision to refund the earnest money along with interest was taken and hence the deduction is allowable.

Urban Improvement Co. (P) Ltd. vs. ITO, ITA No. 3246/Mum/2006, Bench – D, A.Y. 2003–04, dt. 5-9-2008 – BCAJ p. 667, Vol. 40-B, Part 5, February 2009.

12. Business Expenditure – Provision for pay – S. 37(1)

Provision for pay revision based on negotiations with trade unions, as per directions by State Government is allowable as deduction, as liability for pay revision arose, at that point of time though the actual quantification was after approval of MOU by Government of Kerala.

DCIT vs. Travancore Titanium Products Ltd. – 176 Taxman 124 (Cochi)

13. Business expenditure – Violation of Rules & Regulations of National Stock Exchange – S. 37

Violation of Rules & Regulations of National Stock Exchange by its members could not be termed as an offence or as an act prohibited by law. Amount paid as fine by a member of National Stock Exchange to NSE cannot be disallowed u/s Explanation to section 37(1).

Goldcrest Capital Markets Ltd. vs. ITO, ITA Nos. 1240 & 1241/Mum/2006, Bench – B, A.Y. 2003–04, Dt. 21-1-2009, BCAJ p. 795, Vol. 40-B, Part 6, March 2009.

14. Business income – Family Settlement – S. 28(iv)

In terms of family settlement certain shares held by the assessee were to be transferred to Walchand & Co. Pvt. Ltd. However due to certain reasons, the same could not be transferred, by the physical possession of share certificates were handed over to the solicitors. The dividend received during intervening period was shown as liability. The A.O. treated the same as benefit or perquisite chargeable to tax u/s 28(iv). Held that section 28(iv) could be applied only in case where benefit or perquisite was received in kind or when the assessee had credited such amount in P & L A/c. Sec. 28(iv) could be applied only in case where an actual income was received by the assessee in garb of some benefits which were not shown as chargeable to tax.

ACIT vs. Pal Enterprises Pvt. Ltd., ITA No. 1994/Mum/2005, Bench – ‘H’, A. Y. 01 – 02, dt. 20-10-2008 – BCAJ p. 518, Vol. 40-B, Part 4, January 2009.

15. Business of Exploration – Mineral – S. 44 BB

Reimbursement of expenditure relating to supply of raw material is taxable, and cannot be excluded from receipts while determining profit and gains u/s 44 BB, as same is on account of provision of services and facilities.

Whereas reimbursement of expenditure relating to custom duty is not taxable u/s 44BB.

ACIT vs. Transocean Offshore Deep Water Drilling Inc. – 176 Taxman 123 (Delhi)

16. Capital gain – FSI transfer – Ss. 45, 48, 55(2)

The Assessee, a co-operative housing society, owned a land and building. Upon the enactment of Development Control Regulations, 1991 (DCR), it became entitled to additional FSI of around 11,000 sq. ft. which was transferred for the consideration of Rs. 48,96,225/-. Held that right transferred was not covered by any of the items mentioned u/s 55(2) of the Act. Since the right transferred emanated from amendment to DCR and is not covered by any of the items of Sec. 55(2) and does not have any cost of acquisition no capital gain can be charged on transfer of additional FSI.

New Shailaja CHS Ltd. vs. ITO, ITA No. 512/Del/2007, Bench – B, A.Y. 2003 – 04, dt. 2-12-2008 – BCAJ pg. 669, Vol. 40-B, Part 5, February 2009.

17. Capital Loss or Business Loss – S. 50 vis-ΰ-vis S. 32(1)(iii)

On transfer of depreciable asset the excess shall be deemed to be short-term capital gain u/s. 50 whereas loss arising of out of such transfer is allowable as deduction u/s. 32(1)(iii), provided such loss/deficiency is actually written-off in the books of account of the assessee.

Mukund Global Finance Ltd. vs. Dy. CIT

(2009) 309 ITR 294 (AT) (Mum.) / (2009) 117 ITD 20 (Mum)

18. Capital or Revenue – New Technology – S. 37(1)

Expenditure incurred in acquiring new technology to replace existing technology is allowable as revenue expenditure Unidyne Energy Env System Pvt. Ltd. vs. ITO, ITA No. 4007/Mum/2005, Bench – G, A.Y. 2001-02, dt. 10-9-2008, BCAJ p. 796, Vol. 40-B, Part 6,
March 2009.

19. Capital or Revenue – Non-compete fee – Capital – S. 37

Payment towards non-compete fee is not revenue expenditure.

ACIT vs. Real Image Tech. Pvt. Ltd. (2009) 120 TTJ 983 (Chennai)

20. Deduction – Service rendered outside India – S. 80 RRA

While calculating deduction u/s 80RRA, only expenditure directly connected with earning of foreign exchange is to be deducted to arrive at income from foreign exchange earnings. Action of Assessing Officer reducing portion of indirect expenses in addition to direct expenses deleted.

CIT vs. Nishit M. Desai (Mumbai) – 177 Taxman 61

21. Depreciation – Non Compete – S. 32

Amounts paid by way of non-compete fees claimed as revenue expenditure, was treated as capital expenditure. Assessee’s alternate plea to treat same as an intangible asset u/s 32, and consequent grant of depreciation thereon was upheld.

ACIT vs Real Image Tech (P) Ltd. – 177 Taxman 80 (Chennai)

22. Depreciation – Goodwill – S. 32(1)(ii)

Goodwill acquired does not come under the expression “any othet business or commercial rights” of similar nature to know-how, patents, copyrights, trade mark, licences, franchises u/s. 32(1)(ii) and therefore, no depreciation is allowable on Goodwill.

R. G. Keswani vs. ACIT (2009) 308 ITR 271 (AT) (Mum.)

23. Disallowance – S. 40A(3)

Once the payments are covered by Clauses (f) & (I) of Rule 6DD, then it cannot be disallowed under section 40A(3).

Dy. CIT vs. Hind Industries Ltd. (2009) 120 TTJ 505 (Delhi)

24. Disallowance – Shares – Income from firm – S. 14A

It is not possible to hold the view that share income in the hands of partner of a partnership firm is altogether tax free. It is held that share of profit in the hands of a partner is income which has suffered tax in the hands of the firm and found that the share of profit from the firm is exempt from tax u/s 10(2A) not in absolute sense but with a view to avoid double taxation. Accordingly, section 14A is not applicable to the facts of the case.

Hitesh D. Gajaria vs. ACIT, ITA No. 993/Mum/2007, Bench – H, A.Y. 2003 – 2004, dt. 14-11-2008 – BCAJ p. 519, Vol. 40-B, Part 4, January 2009.

25. Disallowance – interest on borrowed capital – S. 14A

Interest on borrowed fund could be disallowed u/s. 14A only when it is used for the purpose of investment in shares which are held as investment or as capital asset by the assessee.

Mukund Global Finance Ltd. vs. Dy. CIT (2009) 309 ITR 294 (AT) (Mum.) / (2009) 117 ITD 20 (Mum)

26. Exemption – Option to claim – S. 10 B

The procedure laid down to avail / or not to avail concession provided u/s 10B are just directory and not mandatory. Held, that letter filed for withdrawing the claim during assessment proceeding cannot be rejected while framing assessment u/s 143(3). Also held that Assessing Officer cannot thrust exemption u/s 10 B.

Techtran Polylenses Ltd. vs. ITO – 177 Taxman 28 (Hyd.)

27. Expenses of Payments to relatives – S. 40A(2)(b)

A bare reading of the provisions reveals that such provision could be invoked only where an expenditure was incurred in respect to which, payment was to be made to sister concern. In case of discount on sales, no payment was made by the assessee as it only reduced the sale price. Therefore relying on the case of CIT vs. Udhoji Shrikrishnadas 139 ITR 827 (MP) held that assessee was not covered u/s 40A(2)(b).

DCIT vs. Orgo Chem Guj. Pvt. Ltd., ITA No.7872/Mum/2004, Bench – H, A.Y. 2001-02, dt. 17-8-2007 – BCAJ p. 520, Vol. 40-B, Part 4, January 2009.

28. Export – Counter Sale Deduction – S. 80HHC

No deduction is available on Counter Sales to foreign tourists in convertible foreign exchange because they did not give any undertaking to take the goods out of India and there was no evidence regarding clearances of transactions through any customs stations in India.

Tribhowandas Bhimji Zaveri (Delhi) P. Ltd. (2009) 308 ITR 18 (AT) (Mum.)

29. Export – DEPB – Excess Provision – Deduction – Ss. 80 HHC, 41(1)

a) Held, that Assessee is entitled for deduction in respect of DEPB credits utilized by the Assessee itself as per first proviso below sub-section (3) of section 80 HHC.

b) Excess provision written back, and considered as business profits u/s 41(1) cannot be considered as in the nature of any other receipt of similar nature as provided in clause (baa) of explanation to section 80 HHC, so as to exclude 90% of such amount for purpose of computing deduction u/s 80 HHC.

Polyplex Corp. Ltd. vs. ITO (Delhi) – 176 Taxman 57

30. Income – Accountant – DEPB – S. 2(24)

The Assessee notionally computed the value of advance licences/DEPB and credited to the Profit and Loss account. In its return of income filed, the said amount was excluded from its income. The A.O. added the same to the income of the assessee. Held that merely because book entries were passed when there was no real income accrued, there was no justification to support the addition. The addition was deleted.

National Leather Mfg. Co. vs. JCIT, ITA No. 8294/Mum/2003, Bench – E, A.Y. 2000-01, dt. 13-6-2008, BCAJ p. 796, Vol. 40-B, Part 6, March 2009.

31. Interest – S. 234B

Once the Assessee was liable to pay Advance Tax from initial stage, the charging of interest u/s 234B on basis of assessed tax is also mandatory.

Flexfit Industries vs. ACIT (Chandigarh) – 176 Taxman 59

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

Interest on amount borrowed for expansion of business though capitalised in the books of account is allowable as deduction.

ACIT vs. Ashima Syntex Ltd. (2009) 120 TTJ 721 (Ahd.)(SB)

33. Interest on borrowed capital – S. 36(1)(iii)

Interest on Capital borrowed for business of investment in shares has to be allowed as deduction.

Peninsular Investment Ltd. vs. Dy. CIT (2009) 120 TTJ 96 (Hyd.)

34. Interest on borrowed capital – S. 36(1)

Interest on funds borrowed for investment in land for business purposes is allowable business expenditure.

Sarnath Infrastructure (P) Ltd. vs. ACIT (2009) 120 TTJ 216 (Lucknow)

35. New Industrial Undertaking – Free Trade Zone – S. 10A

New Industrial Undertaking established by substantial investment in plant and machinery and manufacturing same article would not amount to splitting or reconstruction of the old unit and therefore, it would be entitled to the benefit u/s. 10A.

ITO vs. Servion Global Solutions Ltd. (2009) 308 ITR 375 (AT) (Chennai) / (2009) 116 ITD 133 (Chennai)

36. Notice deemed for valid in certain circumstances – S. 292BB

Provisions of section 292BB have been inserted w.e.f. 1-4-2008 and therefore, it is applicable from A.Y. 2008-09 and it is not retrospective.

Kuber Tobacco Products P. Ltd. vs. Dy. CIT (2009) 310 ITR 300 (AT) (Del.) (SB) / (2009) 117 ITD 273 (Del.)(SB)

37. Notice – Reassessment – S. 143(2)

Held that an order of reassessment passed u/s 147 r.w.s. 143(3) without issue of a valid notice u/s 143(2) of the Act is null and void. The amendment to Sec. 148 by the Finance Act, 2006 does not save the reassessment done without issue of notice u/s 143(2). Further the provisions of Sec. 292BB are prospective and not retrospective.

Chandra R. Gandhi vs. ITO, ITA No. 6006/Mum/2007, Bench – K, A.Y. 2000 – 01, Dt. 23-12-2008 - BCAJ pg. 793, Vol. 40-B, Part 6, March 2009.

38. Penalty – Concealment – S. 271(1)(c)

No penalty can be levied in a case where rental income is assessed under the head ‘Income from house property’ as against ‘Income from Business’

ACIT vs. Vazir Glass Works Ltd., ITA No.332/Mum/2007, Bench – F, A.Y. 2001-02, dt. 24-11-2008 – BCAJ p. 671, Vol. 40-B, Part 5, February 2009.

39. Penalty – Limitation – S. 271B

Since the penalty order has been passed after the expiry of six months from the end of June, 2005, it was barred by the period of limitation.

Motilal Vishwakarma HUF vs. ITO, ITA No.7055/Mum/2007, Bench – B, A.Y. 2003-04, dt. 27-08-2007 – BCAJ p. 520, Vol. 40-B, Part 4, January 2009.

40. Reassessment – Service of notice – S. 148 r.w.s. 143(2)

On the facts and circumstances, the Reassessment was held to be invalid as no Notice u/s. 143(2) was issued.

ITO vs. R. K. Gupta (2009) 308 ITR 49 (AT) (Del.)

41. Return – Defective return – S. 139(9)

The Assessee filed return of loss based on un-audited accounts which was considered as defective. The A.O. asked to file audited accounts within 15 days and rectify the defect. The Assessee requested for two months time and filed the accounts within the time requested for. The Assessing Officer without rejecting the Assessee’s request, treated the original return as defective return and the revised return filed as belated return and rejected the loss. Held that the Assessee’s request for extension of time was if rejected, the order of rejection was never intimated to the Assessee. Thus the original return was treated as valid return and revised return also valid.

ITO vs. PIC (Gujarat) Ltd., ITA No. 3058/Ahd/2002, Bench – B, A. Y. 1990-91, dt. 4-1-2008 – BCAJ p. 519, Vol. 40-B, Part 4, January 2009.

42. Tax Deduction at Source – Fees for profession or technical services – S. 194J

Payments for bandwidth and network services cannot be said to be Technical services liable to TDS u/s 194J

Pacific Internet (India) Pvt. Ltd. vs. ITO(TDS), ITA Nos. 1607 to 1609/Mum/2006, Bench – D, A.Y. 2003-04 to A.Y. 2005-06 , BCAJ p. 795, Vol. 40-B, Part 6, March 2009.