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Showing 61 to 80 of 677 Records
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2007 (2) TMI 665 - MADRAS HIGH COURT
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... ... ..... injured while the State is an impersonal machinery working through its officers or servants.....” 9. On the facts and circumstances of the case, this Court is of the opinion that the delay in filing the Appeal is also not an inordinate delay refusing to exercise the discretion. By refusing to condone the delay, the First Appellate Court has shut out the opportunity of preferring the statutory appeal. The delay in filing the Appeal is to be condoned, so as to afford an opportunity to the Petitioner to pursue the Appeal. 10. For the foregoing reasons, the Impugned order dated 6-12-1999 of the Principal District Dudge, Nagappattinam in I.A. No. 187 of 1999 in unnumbered Appeal is set aside and this civil Revision Petition is allowed. No costs. The connected CM.P. No. 7024 of 2000 is closed. The learned Principal District Judge, Nagapattinam is directed to take the Appeal on file and make over the same to the appropriate court for disposal in accordance with law.
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2007 (2) TMI 664 - BOMBAY HIGH COURT
Suit for specific performance of a development agreement - Non-grant of injunction - denying protections for their right of development of additional 1,00,000 sq.ft. by way of TDR on the suit plot - Whether the appellants have made out a prima facie case that the agreement relied upon was an agreement for sale and not an agreement for security and/or alternatively an agreement for development which could not be specifically performed - HELD THAT:- The learned Single Judge on a consideration of the various documents including the agreement has come to the prima facie finding that the agreement is an agreement to sell, which can be specifically enforced. The respondents, therefore, will have to make out a case that the finding by the learned single Judge is perverse. The view taken by the learned trial Court, ordinarily will have to be upheld,if it was a view capable of being taken, irrespective of the Appellate Court arriving at a conclusion that another view is probable which is a better view and as long as the findings based on which the view is taken are not perverse.
Whether on account of the term in the clause which permits acquisition of slum TDR the Appellants in so far as the additional F.S.I.is concerned, are not entitled for an injunction to that extent - In our opinion, the Appellant in the first instance have a right to use F.S.I. of the property and the S.F.I. by whatever name of the reservations of D.P. Road and/or P.G. of the entire property to the extent of 2,00,000 sq.ft. in terms of the agreements. To that extent the learned single Judge clearly erred in law in clarifying the order. Specific performance can be granted of the land or interest in the land, belonging to a person who has agreed to sell the land with interest therein. If the person is not the owner or has no interest in the land agreed to be sold or transferred there is no question of granting specific performance.
Slum TDR is not interest on the owners property. It is F.S.I. of some other land which is transferable in terms of D.C. Regulations. TDR may be owned by the holder but not the land from which TDR was generated. It can only be used on the owners property in terms of D.C. Regulation. Therefore, it is the F.S.I. of the entire property, including of R.G. and D.P. Road, which alone in terms of the Agreement, prima facie which can be specifically enforced. In such circumstances irreparable loss and injury would be occasioned to the Appellants, if the injunction is not granted. The balance of convenience is in their favour as compensation in money in such cases, would not be adequate. To that extent, we are clearly of the opinion, that the clarification given in the impugned order is liable to be set aside and we accordingly do so.
Whether the Appellants are entitled to right of way as claimed in the Agreement and in the suit - In the instant case this is not an easement of necessity nor an easement by prescription. The only term of the contract was to provide an access. The plot has been sub-divided and the sub-division sanctioned by the Planning Authority. The Appellants are entitled to develop a part of the plot C-2 in terms of the Agreement. Plot No. C-2 has an independent access in terms of the sanctioned sub division. Even in a case of easement of prescription or necessity, the owner can always on the facts of a case alter the access on the same land as long as it is provided on the same property and is easily accessible and does not have any impediments. In our opinion the learned Single Judge prima facie, on the facts, was right in not granting the injunction . We are clearly of the opinion that the Appellants have failed to make out a case irreparable loss or injury at the interim stage, in so far as access is concerned.
Thus, appeal is partly allowed to the extent that we set aside of the impugned order of the learned Single Judge. The Cross Objections are rejected.
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2007 (2) TMI 663 - RAJASTHAN HIGH COURT
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... ... ..... ew of the aforesaid circumstances, the assessee's case clearly fell within the province of s. 80 of the Finance Act, 1994 and truly speaking no penalty was leviable. However, since the assessee and Revenue both failed to notice s. 80 and acted only with a view to levy less or the minimum penalty. The facts and circumstances sterling on the face of the record cannot be ignored. It is also clear from the fact that the assessee has not taken any recourse to challenge the order before Tribunal and had he done so he was likely to succeed and relieved of the whole penalty. 11. On the facts found by the adjudicating authority and in the facts and circumstances of the present case, there is no room for sustaining penalty, even if the answer to the question raised by the Revenue is in the affirmative in their favour. We, therefore, decline to direct Tribunal to refer the aforesaid question for the decision of this case in peculiar facts of the present case. No orders as to costs.
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2007 (2) TMI 662 - CESTAT NEW DELHI
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... ... ..... gement Consultant. (d) Once that is found, & the appellant cannot be classified as a service provider under ‘Management Consultant’ levy of Service Tax cannot visit prior to 2003 or after 2003 under and a ‘Management Consultant’. (e) When there is no levy of Service tax on the appellant, for the Service provided, there was no requirement of registration & filing of returns &/or delay payment of any tax during the period under dispute. The penalties imposed are to be set aside along with the demand of tax as made and interest consequent thereon. 4. A perusal of the above order makes it clear that the appellant’s service, which is identical to the service considered in the above appeal, would also fall under business auxiliary service from July, 2003. In view of this, tax remains correctly paid. Therefore, no question of demand or refund arises. 5. The appeal is ordered accordingly. (Dictated and pronounced in the open court)
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2007 (2) TMI 661 - CESTAT BANGALORE
Dispensation of pre-deposit ... ... ... ... ..... or the reasons pointed out, the appellants have a very strong case on merits and hence prays for waiver of the balance amount. 2.1 Learned DR reiterated the Departmental contentions. 3. On prima facie consideration, we agree with the appellant that supply of personnel cannot be considered as an activity of promotion or marketing or sale of goods as defined under the term “Business Auxiliary Services”. Therefore, ₹ 20 lakhs on this account is not liable to be pre-deposited. For the balance of the amount, the appellants have pleaded time-bar. The appellants were covered already under the service tax and all the details had been furnished to the department. Therefore, prima facie appellants have a strong case for seeking waiver for balance of the amount. Stay application is allowed granting waiver of pre-deposit and staying its recovery till the disposal of the appeal. Appeal to come up for hearing in its turn. (Pronounced and dictated in open Court)
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2007 (2) TMI 660 - KARNATAKA HIGH COURT
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... ... ..... es’ in factory. For the very reason stated in Gwalior Rayon Silk Mfg. Co. Ltd.’s case (supra), we deem it proper to answer even the ‘pipelines’ in favour of the Revenue. 13. Question No. 4 that is referred to us is with regard to gratuity. That very question has been considered by us in ITRC 617/1998 reported as Motor Industries Co. Ltd. v. CIT 2006 206 CTR (Kar.) 23 - Ed. . The said finding in that reference would hold good for this case as well. Following the said judgment, we answer this question in favour of the assessee. 14. In the result, the following order is passed. Question No. 1 with regard to whether the amount paid to GEC was deductible, is answered in favour of the assessee. Question No. 2 is not answered in view of our answer to question No. 1. Question No. 3 with regard to roads, culverts, storage tanks and pipelines, is answered in favour of the Revenue, and Question No. 4 with regard to gratuity is answered in favour of the assessee.
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2007 (2) TMI 659 - PUNJAB & HARYANA HIGH COURT
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... ... ..... me which has escaped tax, the Income-tax Officer’s jurisdiction is confined to only such income which has escaped tax or has been underassessed and does not extend to revising, reopening or reconsidering the whole assessment or permitting the assessee to reagitate questions which had been decided in the original assessment proceedings. It is only the underassessment which is set aside and not the entire assessment when reassessment proceedings are initiated. The Income-tax Officer cannot make an order of reassessment inconsistent with the original order of assessment in respect of matters which are not the subject-matter of proceedings under section 147...." (p. 320) 4. Following Sun Engg. Works (P.) Ltd.’s case (supra), similar view was expressed by this Court in the case of Vipan Khanna v. CIT 2002 255 ITR 2202. 5. Therefore, the question referred is to be answered against the revenue and in favour of the assessee. The reference is disposed of accordingly.
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2007 (2) TMI 658 - ITAT JABALPUR
Income from undisclosed sources - Search and seizure Operation - addition was based on a loose paper No. 7 - dumb document - whether presumption lying under Section 132(4A) can be raised against the assessee - non-speaking order - Notice issued u/s 143(2) - Re-opening of the assessment u/s 148 - HELD THAT:- We notice that the AO could not establish that the assessee has charged any interest, if at all the impugned; figures were advances. There is no material to show that the AO has taxed these advances as wealth of the assessee. There is also no material to show that the assessee has taken any action to recover the money from the alleged debtors. It is not believable that the assessee or his legal heir would forget their money lying with the debtors. By one way or other, he or his legal heir would try to recover the money. The department has not done anything to find out that after the search in April, 1995. We are also unable to satisfy ourselves as to why the alleged transactions are considered in the assessment year 1989-90 when there is no date mentioned on the document. Once search took place in April, 1995, then undated paper could be presumed to be belonging to that period and hence the year of taxability would be assessment year 1996-97. Thus, it is merely by surmises that the AO has taxed it in the year 1989-90.
Thus, a document found during the course of search must be a speaking one and without any second interpretation, must reflect all the details about the transaction of the assessee in the relevant assessment year. Any gap in various components as mentioned in Section 4 of the I.T. Act must be filled up by the AO through investigations and correlations with other material found either during the No. 7 course of the search or on investigation. As a result, we hold that document No. 7 is a non-speaking document.
Since the facts of the present case are similar to the case of Sri Kantilal & Bros., we are of the view that no addition u/s 68 of the Act can be made on the basis of loose sheet being document No. 7 found during the course of the search.
Presumption lying u/s 132(4A) - In our considered view, such presumption is available to the proceedings u/s 132(5). In Section 278D, a separate presumption has been provided for invoking in prosecution proceedings. As no such presumption is provided in assessment proceedings, we infer that where the Legislature intended to provide such presumption it has been so provided in various Chapters. In Chapter relating to search and seizure that presumption about books of account and documents is provided but it is limited to the summary proceedings about retention or release of the assets u/s 132(5). This cannot be extended to assessment proceedings. Our view is supported by the decision of the Hon'ble Supreme Court in P.R. Metrani v. CIT [2006 (11) TMI 136 - SUPREME COURT].
Thus, the case of the Revenue is not assisted by Section 132(4A) in any way. Even otherwise our considered view is that such presumption can only be raised when document is speaking one and it reflects complete transactions without two interpretations.
As a result, we hold that the impugned document No. 7 is a dumb document and no addition an be made on that basis. Therefore, we confirm the order of the Ld. CIT (A) and dismiss the appeal filed by the revenue.
Re-opening of the assessment u/s 148 and addition on the basis of a seized loose paper No. 9 - We find that there is a direct nexus of the material available with the AO with the formation of the belief. Once it is done, in our considered view the reopening is justified. As a result, we reject the contention of the ld. A.R. in this regard. We uphold the order of ld. CIT (A) wherein he has confirmed the re-opening of the assessment. This ground of the assessee is, therefore, rejected.
It also does not show that the assessee has, in fact, advanced Rs. 20,000 or for that matter Rs. 5,30,000 on various dates. Thus, on the basis of same reasoning as we have given in respect of document No. 7 in revenue's appeal, we hold that the document No. 9 also is non-speaking so far as entry of Rs. 20,000 or for that matter entry of Rs. 5,30,000 being the total of various entries are concerned. It is not established by the AO that they are monies advanced. It is also not established that they are not recorded in the regular books of accounts. It is also not established that they relate to the assessee.
As held in Revenue's appeal, presumption u/s 132(4A) cannot be raised in assessment proceedings. Thus, following our own reasoning in Revenue's appeal, the addition sustained by the Ld. CIT (A), in our view, is incorrect and the same is, therefore, deleted.
Unexplained investment - search and seizure operations - found loose paper - HELD THAT:- The nature of transaction is clear that they are purchases. The date is available i.e. 27.6.1992 and finally the quantum of expenditure is also clear i.e. Rs. 1,31,736. Thus, there is no room for any doubt and therefore, we are of the considered view that lower authorities were justified in treating this amount as expenditure/investment and as no explanation was forthcoming, it was rightly treated as unexplained investment. It was for the assessee to submit cogent material so as to show that inference drawn by the AO was incorrect. It was for him to bring evidence from the concerned party that it is not a purchase but only a quotation. Since no such material was produced by the assessee, the onus shifted back to the assessee, remained undischarged. As a result, we confirm this addition. This ground of the assessee, therefore, fails.
Notice issued u/s 143(2) - assessment completed u/s 143(3) - We are of the view that there is no merit in the argument of the Ld. A.R. It is because there has been amendment in Section 148 wherein issuance of notice u/s 143(2) after expiry of 12 months is no longer required and in absence of issuance of such notice within 12 months, the assessment will not be declared invalid. This amendment was introduced by the Finance Act, 2006 with retrospective effect from 1.10.1991. Even otherwise, our view that assessment cannot be annulled merely because notice u/s 143(2) was issued beyond 12 months in re-assessment proceedings initiated under Section 148(1) finds support from the decision of I.T.A.T. Amritsar Bench in the case of Sharma and Co. v. ACIT, [2004 (6) TMI 242 - ITAT AMRITSAR].
After the amendment by Finance Act, 2006, the view was explicitly made clear that time limit for issuance of notice u/s 143(2) will not apply in re-assessment proceedings. Therefore, this additional ground taken by the assessee has no force and hence fails. As a result, this ground of the assessee is dismissed. As a result, the appeal filed by the assessee is partly allowed.
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2007 (2) TMI 657 - ITAT BANGALORE
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... ... ..... he Kerala High Court in the case of P.N. Sasikumar vs. CIT (1988) 69 CTR (Ker)78 (1988) 170 ITR 80 (Ker) in support of our finding. 25(v). The assessee, in this case, had raised preliminary objection that no notice under s. 148 was served on him and no effort was made by the Revenue to address this specific averment of the assessee. Thus on facts and circumstances of the case we have to quash the order dt. 28th March, 2002 passed by the AO under s. 144 r/w s. 147 of the Act for asst. yr. 1995-96 for the reason that no notice under s. 148 reopening the assessment in terms of s. 147 was served on the assessee. 26. As we have cancelled the assessments on the ground that reopening itself is bad in law, we do not find it necessary to dispose of the other grounds of appeal for the reason that it would be an academic exercise. In the result, appeal of the assessee for asst. yr. 1998-99 is allowed in part to the extent indicated above and the appeal for asst. yr. 1995-96 is allowed.
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2007 (2) TMI 656 - MADRAS HIGH COURT
Addition on account of receivable interest on amounts advanced to the subsidiary company - HELD THAT:- In the instant case, the Tribunal, after careful analysis of the materials available on record found that no fresh loan was given by the assessee to its sister concern during the relevant assessment year and moreover, similar claim of allowance of interest paid on borrowings as interest referable to the advances given to its subsidiary company was allowed during the earlier assessment years, and the same remains unchallenged till date. In our considered opinion, such finding given by the Tribunal based on valid materials, does not warrant interference.
Payment of incentives to Dock Labour Board workers - HELD THAT:- The first appellate authority as well as the Tribunal found that there is no breach of law in making payments which were essentially incidental to the carrying of the appellant's business with a view to earning profits, and such finding given by both the authorities, after wading through the materials available on record, in our considered opinion, needs no interference.
Expenditure as loose tools written off - HELD THAT:- The reasoning of the CIT (Appeals), which was confirmed by the Tribunal, was based on appreciation of the materials on record, which revealed that the assessee had not sold such tools and if and when such tools are sold, the same would be brought into the profit and loss account. Such finding, based on appreciation of facts, in our considered opinion, warrants no interference. Hence, this substantial question of law needs no consideration.
Addition on interest/clearing and handling receipts, stevedoring receipts, agency fees, service charges - HELD THAT:- The Tribunal had consistently held the above issue in favour of the assessee and the Revenue had accepted the earlier order and counsel for the Revenue had not produced any material or evidence before us to take a different view. When a consistent view has been taken by the Tribunal, there is no error or infirmity in the order of the Tribunal and it does not require interference and hence no substantial question of law arises for consideration.
In the result, finding no substantial question of law arising for our consideration, these appeals are dismissed. No costs.
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2007 (2) TMI 655 - ITAT DELHI
Tax interest granted on enhanced compensation - quantum of enhanced compensation - HELD THAT:- We find that in the present case the assessee has already received the enhanced compensation as we as interest on such enhanced compensation. HUDA who has acquired the land has not challenged the quantum of enhanced compensation in further appeal. Only the landowners have challenged the compensation granted in this regard. Thus the amount of interest which has already been received is not going to be recovered back. Thus to the extent of amount already received, the same has attained finality and hence in view of the decision of Special Bench of the Tribunal in the case of Dy. CIT v. Padam Prakash (HUF) [2006 (9) TMI 222 - ITAT DELHI-E] the interest actually received has to be brought to tax. This ground is accordingly to be dismissed in all the cases.
Denial of exemption u/s 54B r/w section 54H - HELD THAT:- Investment in the new agricultural land by the assessee in the name of their family members cannot be a bar for granting exemption u/s 54B/54H of the Act. So long as the consideration has passed from the consideration received on transfer of asset, deduction has to be granted considering the spirit of the provision. We accordingly hold that in view of the discussion and in view of the decision of the Tribunal in Babu Ram v. ITO [2004 (2) TMI 285 - ITAT DELHI-A], the assessee is entitled to deduction u/s 54B/54H of the Act. The Assessing Officer shall verify that the assessee has invested in agricultural land based on the land records as may be produced by the assessee before him. If it is found that the assessee has acquired agricultural land, the assessee should be held eligible for exemption u/s 54B/54H of the Act.
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2007 (2) TMI 654 - CESTAT MUMBAI
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... ... ..... the High Court had directed that this position be clarified by the CBEC and the matter was clarified as above by the Board in June 2001. In these circumstances it cannot be held that the respondent knew or must have known that their rendering of financial advisory services for merger and acquisition of companies was in the nature of the management consultancy services so as to attract liability to service tax and that therefore, not paying service tax during the period in dispute amounts to suppression of the fact that they were management consultant with an intention to evade payment of duty so as to make available to the department, the extended period of limitation. In this view of the matter, we agree with the finding of the Commissioner (Appeals) that in the present case, the extended period of limitation cannot be applied against the assessee and that the demand is barred by limitation and accordingly uphold the impugned order and reject the appeal. (Dictated in Court)
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2007 (2) TMI 653 - MADHYA PRADESH HIGH COURT
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... ... ..... as allowed in the previous year, it was not open to the assessee to claim reduction with regard thereto for determining whether the total income should be quantified under Section 115J(1). 13. In view of the above decision of the Supreme Court, with great respect, we differ from the decision of Bombay High Court in Kinetic Motors Co. Ltd. (supra) insofar as it holds that the straightline method can be bypassed to switch over to the method of WDV with retrospective effect. We are of the considered view that though under the Companies Act, the assessee has the option of adopting straightline method and WDV method for claiming depreciation, the change from one method to another has to be prospective. Under these circumstances, our answer to the question No. 2 is that the depreciation, upon change of method, can be claimed prospectively only from the date the change has been effected. 14. In view of the foregoing discussion, this appeal is disposed of with no orders as to costs.
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2007 (2) TMI 652 - DELHI HIGH COURT
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... ... ..... the assessment year 1996-97 and the Assessing Officer made no addition to the income of the Assessee for that year. Under these circumstances, we are of the view that no substantial question of law arises in so far as the investment of ₹ 60 lacs by M/s Gold Mark Enterprises Ltd. is concerned. It may be noted that in so far as the assessment year 1995-96 is concerned, learned counsel for the Assessee pointed out that the amount is ₹ 40 lacs and not ₹ 60 lacs. The second issue that has been raised by the Revenue does, in our opinion, raise, a substantial question of law and we admit the appeal to that extent and frame the following question of law - Whether the Income Tax Appellate Tribunal was correct in law in holding that the Assessee was entitled to deduction under Section 80-IA of the Income Tax Act, 1961?? Paper books be filed in accordance with the High Court rules. Liberty is granted to the Assessee to file the paper book that was before the Tribunal.
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2007 (2) TMI 651 - BOMBAY HIGH COURT
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... ... ..... . 60. Following the aforesaid decision, this Court in the case of Primella Sanitary Products (Supra) and Auto Ignation (supra) held that where any dispute as to whether an exemption notification is applicable or not, then the application would not be maintainable before this Court. The decisions relied upon by Mr. Jetly do not support the case of the revenue, because in the case of ITC Limited (Supra), the applicability of a notification was not an issue and in the case of Amar Bitumen & Allied Products Pvt.Ltd., the question as to whether appeal was maintainable before the High Court or before the Supreme Court was not an issue. Thus, both the decisions relied upon by Mr. Jetly do not support the case of the revenue. 61. Accordingly, in the light of the Apex Court in the case of Navin Chemicals (Supra), we are of the opinion that the application filed by the revenue is not maintainable before this Court. In the result, application is dismissed with no order as to costs.
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2007 (2) TMI 650 - SUPREME COURT
Interpretation and application of Sections 31, 32 and 56 of the Indian Stamp Act, 1899 (for short "the Act"), as amended by the State of Madhya Pradesh, and are applicable in the State of Chhattsigarh
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2007 (2) TMI 649 - CESTAT NEW DELHI
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... ... ..... d., 2006 (3) S.T.R. 204 (Tri.-Del.). 4. After hearing both the sides and on perusal of records, I find that this Tribunal in the case of J.K. Industries Limited (supra) rejected the refund of Service tax. It is held that there is no question of issuance of any Show cause notice under Section 73 of Finance Act, 1994 for recovery. The present case related to recovery of Service tax under Section 73 of Finance Act, 1994, wherein the liability to file return is cast on the appellant only under Section 71A of the said Act. So, prima facie the decision of the Tribunal in the case of J.K. Industries Limited (supra) is not applicable herein, in other words, the case of L.H. Sugar Factories Ltd. (supra) is applicable. As such, the applicant is able to make out a prima facie case for waiver of pre-deposit of entire amount of tax and penalty. Accordingly the stay application is allowed and the requirement of pre-deposit of tax and penalty is waived till the disposal of the appeal.
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2007 (2) TMI 648 - CESTAT NEW DELHI
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... ... ..... ellant had not paid the Service Tax, therefore, are liable for penal action. The respondent filed written submissions and placed on record copy of the order passed by the Tribunal in the case of CCE v. Bhojpur Club Final Order No. 321/06 dated 14-2-2006 where the Tribunal in a similar situation dismissed the appeal. 4. I have gone through the impugned order and the decision of the Tribunal relied upon by the respondent. I find that after taking into consideration Voluntary Disclosure Scheme dated 23-9-2004 held that when the assessees who did not at all complied with the provisions of Service Tax Law but paid the tax along with interest are not liable for penalty and there is no tangible and logical reason as to why the law abiding assessee who had got himself registered and also started paying Service Tax along with interest should be denied the benefit of waiver of penalties. In view of the above decision, I find no infirmity in the impugned order, the appeal is dismissed.
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2007 (2) TMI 647 - CESTAT AHMEDABAD
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... ... ..... f penalty, I find that the whole project has been carried out under aegis of the Government of India, Ministry of Power. There was a genuine belief that at the time of clearance of the goods that the World Bank would finance the project and this belief has been vindicated in May 2004, when World Bank has made the payment towards the project”. The Notification No.108/95-C.E. do not prescribe any particular time limit to fulfil the conditions of the exemption Notification. World Bank funding which is a requirement for having availed the exemption has come through knocking out foundation of the show cause notice/order-in-original. 7. Therefore, following the ratio of the order of the Bangalore Bench in the case of Deepak Cables (India) Ltd. (supra) and the order of the Mumbai Bench in the case of Power Grid Corporation of India Ltd. (supra), the present appeal is allowed. (Operative part of the order was pronounced in the open Court at the end of hearing on 6-2-2007)
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2007 (2) TMI 646 - CESTAT MUMBAI
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... ... ..... payment of service tax as it was being made directly by the appellant to the Revenue. In an identical case decided by CEGAT, Delhi vide order No. 04/2003-NR(A), dated 2-6-2003, the Tribunal has taken a view to waive the interest in the appellant’s own case of Chandigarh unit. Applying the same ratio as held by the Delhi Tribunal, this appeal is disposed off by setting aside the impugned order. Consequently the interest amount of ₹ 1,78,153 is hereby waived. Order accordingly.
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