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Income Tax - Case Laws
Showing 321 to 340 of 515 Records
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2013 (8) TMI 518 - ITAT AHMEDABAD
Disallowance of interest expenditure - CIT upheld proportionate interest - Held that:- Assessee has granted interest free loan to a related party - there was sufficient fund available with the company in the form of reserves and surplus. Further nothing has been brought on record by Revenue to prove that interest bearing loans taken by the Assessee for the purpose of own business has been diverted for non business purposes or for lending to related party - No direct nexus has been proved either by Assessing Officer or by CIT(A) between the interest bearing loans taken and the interest free loans granted - If there are funds available both interest free and over draft and or loans taken than a presumption would arise that investment would be out of interest free fund generated or available with the company, if the interest free funds were sufficient to meet the investment - No disallowance can be made - Following decision of CIT vs. Raghuvir Synthetics [2013 (7) TMI 806 - GUJARAT HIGH COURT] - Decided in favour of assessee.
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2013 (8) TMI 517 - ITAT DELHI
Validity of assessment proceedings - Assessment on Amalgamated company - CIT quashed assessment proceeding - Held that:- assessee had amalgamated with another company and assessee had participated in assessment proceedings - Proceedings in this case was initiated by virtue of search and seizure operation - Assessment on a company which has been dissolved and struck off the register of companies u/s 560 of the Companies Act,1956, is invalid, even though the company participated in assessment proceedings- There is no provision in the IT Act to make assessment on a dissolved company-it is not a case of discontinuance of business so as to attract section 176 nor does Section 159 cure the lacuna - Following decision of IMPSAT (Pvt.) Ltd. vs ITO ITAT, Delhi 'A' Bench [2004 (7) TMI 299 - ITAT DELHI-A] - Decided against Revenue.
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2013 (8) TMI 516 - ITAT AHMEDABAD
Penalty u/s 271(1)(c) - Application for reduction of penalty u/s 273A - Long term capital gain - Sale of ancestral property - CIT upheld penalty - Held that:- it is seen that the penalty was deleted by the Tribunal in the case of late Harshadrai Contractor, i.e. father of these two assessees, and also in the case of Shri Balvantrai S. Contractor, uncle of these two assessees, who was co- owner of this land having 73% right of ownership. - long term capital gain was not declared in the regular return of income by these assessees and the same was declared along with petition filed by the assessee under section 273A of the I.T.Act.
Following decision of Late Harshadrai Contractor Through L/H. Paresh Contractor v. Income-Tax Officer [2013 (7) TMI 823 - ITAT AHMEDABAD] - Decided in favour of assessee.
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2013 (8) TMI 515 - ITAT AHMEDABAD
Penalty u/s 271(1)(c) - Confirmation not filed - CIT reduced penalty - Held that:- Assessee had furnished stock register to show the day-to-day purchase and sale of goods - addition made by the AO and reduced by the appellate authorities was on estimation basis - Following decision of M/s.Rolex Tin Works Vs. ITO [2013 (7) TMI 824 - ITAT AHMEDABAD] - Decided in favour of assessee.
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2013 (8) TMI 514 - ITAT DELHI
Deemed dividend u/s 2(22)(e) - A.O. made addition on account of debit balance of account - Held that:- there was opening credit balance, then debit balance occurred due to certain payments made by M/s Daisy Motors Pvt. Ltd. to the assessee in the month of April and July. Thereafter, from July 2005 to 22nd March, 2006, there was a credit balance and again on 30th March, 2006, there was a debit balance - From the copy of account, it is evident that the assessee also made purchase of ten vehicles. Thus, the account is clearly in the nature of a running current account and merely because for a few days there was a debit balance of it cannot be said that such debit balance was either loan or advance by M/s Daisy Motors Pvt. Ltd. to the assessee - Following decision of CIT Vs. Creative Dyeing and Printing P.Ltd. [2009 (9) TMI 43 - DELHI HIGH COURT] and CIT Vs. Ambassador Travels P.Ltd. [2008 (4) TMI 428 - DELHI HIGH COURT] - Decided in favour of Assessee.
Unexplained expenditure - Household expenses - Held that:- considering the size of the assessee's family and the status of the assessee, the estimate of household expenditure of ₹ 30,000/- per month is quite fair and reasonable - while considering the household expenditure, withdrawal by the assessee's wife should also have been considered - Addition on account of unexplained expenditure reduced - Decided against Assessee.
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2013 (8) TMI 513 - ITAT DELHI
Capital receipt or Revenue receipt - Entertainment tax subsidy - CIT held it as capital receipt - Held that:- Ld. CIT (A) in the year before us, has deleted the disallowance by observing that similar additions for Assessment Year 2006-07 and 2007-08 were deleted by the CIT (A) by referring to, inter alia, 'Ponni Sugar' (2008 (9) TMI 14 - SUPREME COURT) and that the facts and circumstances in the years under consideration were similar to those in the earlier years. This has not been disputed - Decided against Revenue.
Capitalization of advertisement expenses - enduring nature - CIT deleted the addition on account of capitalization of advertisement expenses - Held that:- Ld. CIT (A) has deleted the addition on merits and it is therefore, that he has not gone into the alternative issue raised by the assessee. - Decided against Revenue.
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2013 (8) TMI 512 - ITAT DELHI
Rejection of books of accounts - A.O. made addition on various grounds rejecting books of accounts - CIT deleted addition - Held that:- assessment order of 2005-06 & 2006-07 and from the assessment order under consideration find that the Assessing Officer has rejected the books of accounts by holding similar findings and has not brought out any defect in the books of accounts. The Assessing Officer has rejected the books of accounts and made addition on account of suppression of production on the basis of assumption only - There is discrepancy in the submissions of assessee regarding increase in prices of raw material and decrease in prices of finished goods. He did not point out any defect in the stock register or in the prices of raw material and finished goods as claimed by the assessee - Decided against Revenue.
Disallowance of freight, octroi and cartage expenses - proper vouchers and bills not produced - Held that:- Assessing Officer has every right to look into the genuineness of expenses claimed by the assessee and in the absence of non production or inadequate documentary evidence in support of expenses claimed can disallow a part of expenses after recording finding of facts. He has every right to call for explanation and in view of non explanation he is empowered to make reasonable disallowance keeping in view the facts and circumstances of each case - Assessing Officer is directed to obtain the vouchers/bills of these expenses and ascertain the genuineness of the same and disallow amounts under these heads if any on a reasonable and authentic basis - Decided in favour of Revenue.
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2013 (8) TMI 496 - ITAT MUMBAI
Penalty to be levied u/s 271(1)(c) of the Income Tax Mens rea is not present Held that:- Making an incorrect claim does not tantamount to furnishing inaccurate particulars and that to attract penalty, the details supplied in the return must not be accurate, not exact or correct, not according to the truth or erroneous - Facts reveal that details supplied by the assessee did not fall in any of these categories Delete the penalties u/s 271(1)(c) Decided in favor of Assessee.
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2013 (8) TMI 487 - AUTHORITY FOR ADVANCE RULINGS
Bar provided in section 245R(2) of the Income Tax Act for filing application before Advance Rulings Held that:- As per decision in the case of Sepco III Electric Power Construction Corporation, In re (No.1). [2011 (8) TMI 213 - AUTHORITY FOR ADVANCE RULINGS], where a return has been filed by the applicant for advance ruling and notice under section 143(2) was issued, the matter shall be treated to be pending before the Assessing Officer, so that any issue in respect of such return cannot be entertained for advance ruling under section 245R(2) of the Act.
When notice u/s.143(2) is issued, all the informations available in the return and claims thereon are subject to adjudication by the Assessing Officer and several issues emerge for adjudication by the Assessing Officer - With issue of notice u/s.143 (2) of the Act, particulars of income, claims of the assessee in the return are pending for adjudication before the Assessing Officer - Question raised in the application for advance ruling is pending adjudication before the assessing authority and the bar created under the proviso to section 245R (2) clearly operates. Therefore, these applications are not admitted for adjudication and stand rejected - Decided against the Assessee.
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2013 (8) TMI 486 - ALLAHABAD HIGH COURT
Penalty under section 271D of the Income Tax Act Violation of bar provided by Section 269SS of the Act, which provides all transactions above Rs.20,000/- to be made through banking channels Held that:- There is no evidence to show that there is urgent requirement of the fund for purpose of repaying to the bank - There is no deadline set by the Bank for repayment of the loan amount - Assessee had taken loans from four individuals in cash of Rs. 2 lacs each in violating Section 269SS of the Act - Section 273-B, in an exception to Section 269-SS, and provides that no penalty is imposable on the person or assessee as the case may be for any failure referred to in the said provisions (including Section 269-SS), if he proves that there was reasonable cause for the said failure Held that:- The assessee, could not satisfactorily give explanation for the alleged hurry in which he had to arrange the money to be deposited in bank for release of the property - The findings, whether there was any reasonable cause for non-compliance of Section 269SS are findings of fact. The Tribunal is the last forum for recording such findings - All the Income Tax authorities including the Tribunal have concurrently held that there was no reasonable cause inasmuch as the story set up by the assessee to arrange the money in hurry to save the honour of the family was not proved, the assessee would not get the benefit of Section 273B of the Act Decided against the Assessee.
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2013 (8) TMI 485 - ALLAHABAD HIGH COURT
Transfer of case - Section 127 (4) - Requirement for reissue of notice for reassessment u/s 147 - Held that:- There was no search and seizure operation nor any coordinate investigation was required as there was no group of companies nor any incriminating material was seized at any place or places. It was during the course of assessment made by ACIT, NOIDA, who had assumed jurisdiction on the ground that he alone could have assessed the assesee as they had their office and business place in NOIDA, the order under Section 127 (2) was obtained by making efforts. According to A.O. the assessee was seeking repeated adjournments.
In the circumstances, it cannot be said that the assessee was either absconding from proceedings or was not available so as to form any opinion that service of notice was not possible. The assessee had filed objections, which was directed to be decided by the High court - Reasons given by CIT (A) in deciding the objections were not sufficient as the transfer of jurisdiction was made on the request of A.O. to which objections were filed and were not decided by the A.O - Mandatory for the A.O. to decide objections and that the exercise of discretion on the objections would in any case not validate the notice under Section 147/148 of the Income Tax Act Decided against the Revenue.
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2013 (8) TMI 484 - ITAT JODHPUR
Rate of allowance of interest expenditure Held that:- Assessing Officer himself made the disallowance @ 12% in the succeeding year i.e. 2007-08. It was claimed that the facts for the year under consideration were similar with the facts involved in the assessment year 2007-08. The learned CIT(A) also pointed out that in another comparable case having similar facts, the Assessing Officer himself disallowed the proportionate interest @ 12% - Allowance of interest expenditure @ 12%.
Allowance of expenditure in relation to insurance charge and registration fee of vehicle Held that:- A.O. disallowed all the expenses incurred by the assessee on account of insurance and registration charges for the assets acquired first time during the year under consideration A.O. ignored this vital fact that insurance charges were to be paid year after year annually so those were revenue in nature. In the instant case, it is not the case of the Assessing Officer that those expenses were not incurred for the business purposes, therefore, the Learned CIT(A) was fully justified in deleting the disallowance to the extent of Rs. 5,55,033/-, which related to the annual insurance expenses Revenue appeal rejected Decided against the Revenue.
Valuation of closing stock - The facts related to this issue in brief are that the Assessing Officer noticed that the assessee had shown closing stock of Rs. 2,15,95,145/- in the trading account of IMFL/Beer - The permit fees, which was payable on per bulk liter basis had not been included in the valuation of closing stock Held that:- Assessing Officer was not justified in treating the permit fee relating to the transmission of the stock from godown to the shops as a part of the closing stock. Moreover, whatever permit fee was paid by the assessee that was for the sale materialised, therefore it could not have been added while valuing the closing stock, which was to be surrendered/ returned on the next day following the end of the year to the Excise Department/distillery at cost price Revenue appeal dismissed Decided against the Revenue.
Depreciation on written down value of the carats - Assessee in the revised depreciation chart claimed the depreciation at Rs. 37,000/- on carats, based on the adjustment made on account of excess depreciation claimed in the assessment year 2005-06 - Assessee had claimed depreciation on carats @ 100%, however, it was allowable @ 50% - Held that:- Depreciation on carats as claimed by the assessee is allowed - As the A.O. has already allowed 50% depreciation, there remains the W.D.V. at Rs. 16,74,000/- for the year under consideration. Therefore, the appellant is entitled for depreciation @ 50% on the W.D.V. of carats. The A.O. is directed to allow depreciation on carats as claimed by the appellant.
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2013 (8) TMI 483 - ITAT MUMBAI
Application of percentage completion method for computation of profit real-estate business Held that:- Clearly, there is no question of any income unless the sale or transfer has taken place, so that the builder-seller retains no effective control of the real estate, i.e., to the degree as usually associated with the ownership, which is thus beneficially transferred. This essential condition for recognizing income being satisfied, the next step would be to determine the extent to which it could be so. We have already explained of the fundamental accounting assumptions of conservatism and prudence, which are to necessarily inform the accounting estimates and statements and, in fact, stand also statutorily recognized per the accounting standards issued by the CBDT u/s. 145 of the Act.
Regarding cost plus method and valuation of WIP - Unsold project - Held that:- No income can be anticipated in respect of the part of the project yet to be sold (i.e., as at the relevant year- end), so that it would be, from the stand point of reporting profit on the project, be immaterial if the sale price, as is generally the case, has increased over the period since which the project stands commenced. - if there is a sudden depression in the real estate market. If the Management considers that it cannot hold on to the project, the subsequent sales would have to be necessarily estimated at the going market rate. The same, if lower than the cost as anticipated, would impact the valuation of the WIP. This would depress the overall profit, which though, as evident, has no direct relation with the costs incurred during the year, i.e., the incremental WIP for the year.
The assessee has furnished a revised chart (Table C) by eliminating the profit included in the valuation of the closing stock, so that it is valued at cost, which shows the profit on the project at 40.22% of the total cost. In view of the fact that some percentage of the total cost remains to be incurred as at the year-end, which though could be fairly assessed, in our view, adopting the said percentage (of course upon verifying the same to be correct) to the incremental cost for the year would be a fair assessment of the profit arising for the current year. As the assessee has booked the cost of land and utilities in some years, in preference to others, without furnishing any explanation for the same, much less a reasonable one, in our view, the cost of land and utilities, i.e., the basic costs, since incurred, be allotted to each year in proportion to the other costs incurred in that year. That is, a ratio of the basic cost (total) to the other (total) costs (for the entire project) be worked out, which percentage would then be applied for each year, including the current year, in proportion to the other cost for that year.
The A.O. is accordingly directed to verify the afore-mentioned ratio of 40.22% as worked out by the assessee, and apply the said percentage - Decided partly in favor of assessee.
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2013 (8) TMI 482 - ITAT MUMBAI
Unexplained credit u/s 68 - The addition made to the returned income, for which the penalty stood levied, is u/s.68 Held that:- Explanation, if any, offered in establishing the genuineness of the credits, is essentially a matter of fact - The only explanation offered by the assessee in the quantum proceedings, which is itself a matter of fact, was that the said credits in fact pertain to an earlier year, and which was found on verification as incorrect on facts, so that the additions stood confirmed Decided against the Assessee.
Issue involved is primarily factual, i.e., whether the assessee has been able to satisfactorily prove the impugned credits as to their representing the assessee's genuine liabilities or not.If and to the extent it has been, its return of income does not bear any concealment or inaccurate furnishing of any particulars of income, so that no penalty u/s.271(1)(c) could be levied. The law placing the onus to prove the credits on the assessee, a failure to do so would invite addition in its respect as unexplained income u/s.68. Further, that the addition has been made under the deeming provision of section 68 is no bar for the levy of penalty.
Penalty proceedings u/s 271(1)(c) Held that:- Assessee has been able to adduce some evidences toward establishing the credits as representing genuine liabilities - Accepting or rejecting the assessee's claim is based on appreciation of those evidences, forming part of the assessee's explanation, and for which reference is made to a series of decisions by the apex court, as follows - In sum, decision in the instant case is based purely on findings of fact; the law in the matter being well settled and trite: CIT v. Atul Mohan Bindal [2009 (8) TMI 44 - SUPREME COURT]; Union of India v. Dharmendra Textile Processors [2008 (9) TMI 52 - SUPREME COURT] etc. - Penalty deleted. - Decided in favaor of assessee.
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2013 (8) TMI 481 - ITAT MUMBAI
Computation of income from contract receipts - contract completion method - issuance of provisional acceptance certificate - Held that:- fees received for the contract work was being offered by the assessee by following the percentage completion method and the said method consistently following by the assessee was accepted by the Department in the earlier year. As per the said method, 98.54% of the total contract work was shown to be completed by the assessee upto 31-3-2006 and accordingly the corresponding income was offered to tax in the year under consideration. The A.O. as well as the ld. CIT(A), however, took the contract as fully completed up to 31-3-2006 mainly on the basis of provisional acceptance certificate issued by the owners taking a stand that the assessee having become entitled to receive the entire contract fees on the issue of provisional acceptance certificate, income to that extent had accrued to the assessee and the same was taxable in the year under consideration - The said list, is sufficient to show that the work as per the contract was not completed by the assessee up to the date of issuance of provisional acceptance certificate and the assessee was still not relieved of the obligations under the contract as made clear in the certificate itself. The provisional acceptance certificate also made it clear that the same did not constitute final acceptance of the work and as per clause 25.1 of the contract, the assessee was entitled to apply to the owner for its final acceptance certificate upon completion of pending items identified in the provisional acceptance certificate to the satisfaction of the owner. The said final acceptance certificate was issued by the owner only on 26-3-2007 and even the said certificate indicating the effective final date as 8-10-2006 was subject to certain defect and deficiencies as set out in the Appendix A to the certificate which were required to be rectified by the contractor - Therefore, it is held that contract work was finally completed in the subsequent year and the disclosure made by the assessee of its income by showing 98.54% work completed upto 31-03-2006 and offering the income relating to the balance work in the subsequent year i.e. A.Y. 2007- 08 was in consonance with the method of accounting consistently followed by it to recognize its income from execution of contract work - Decided in favour of assessee.
Disallowance of professional fees u/s 40(a)(ia) - Provision for Auditor's remuneration - Held that:- if the auditors remuneration and the services availed in transfer pricing matter were related to the year under consideration, the same cannot be disallowed on the ground that the relevant services were rendered after the end of the previous year - Decided in favour of assessee.
As regards the applicability of section 40(a)(ia) of the act, assessee has relied on the decision in the case of Pfizer Limited (2012 (11) TMI 164 - ITAT MUMBAI) wherein it was held, following the decision in the case of IDBI vs. ITO (2006 (7) TMI 248 - ITAT BOMBAY-H), that when payee is not identifiable at the time of making provision, no TDS need to be made. - the stand of the assessee that the concerned payees were not identifiable at the time of making the provision is required to be verified keeping in view that the auditors generally are appointed in the relevant financial year itself. - Matter remanded back.
Disallowance u/s 40(a)(ia) - Held that:- It is also not the case that assessee has not deducted any amount. Assessee has indeed deducted tax under section 192 and so we are of the opinion that provisions of section 40(a)(ia) also do not apply as the said provision can be invoked only in the event of non deduction of tax but not for lesser deduction of tax - Following decision of DCIT vs. Chandabhoy & Jassobhoy [2011 (7) TMI 956 - ITAT MUMBAI] - Decided in favour of assessee.
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2013 (8) TMI 480 - ITAT CHENNAI
Disallowance of preliminary expenditure - expansion of its existing line of business - CIT confirmed disallowance - Held that:- business which was being set up by the assessee at Trivandrum was only an expansion of its existing line of business. - At both place, assessee was only developing software for educational purposes. Once expenditure was of revenue nature and was incurred for expanding existing line of business, in our view, it could have been allowed under Section 37 of the Act. No doubt, assessee's claim was only for one-third of total outgo. However, for this reason alone, a disallowance could not have been made - Decided in favour of assessee.
Gratuity payment of M/s LIC - CIT disallowed the claim of the assessee - Held that:- There is no dispute that premium towards Gratuity Fund was paid by the assessee to LIC and the Gratuity Fund created by LIC by virtue of such payments, was not having the approval of CIT/CCIT under Section 36(1)(v) of the Act. Nevertheless, it is also a fact that assessee had filed an application before CIT for such approval on 12.4.2002. - unless there was strict compliance to Section 40A(7), an assessee could not claim for relief any amount or payment of premium to M/s LIC for any Group Gratuity Scheme - conditions mentioned in Section 36(1)(v) was held to be satisfied since the funds ultimately came back to a Gratuity Fund had the approval of the Commissioner. Here, the fate of the application of the assessee for approval is not known - If the assessee is able to produce the approval for Gratuity scheme, no doubt, it can claim deduction under Section 36(1)(v) of the Act and will not be fettered by constraints placed under Section 40A(7) of the Act - Decided in favour of assessee.
Deduction u/s 10B - CIT disallowed deduction - Held that:- if the assessee is able to produce FIRC for whole of the receipts on account of export proceeds, it will be unfair to deny the claim made by it under Section 10B of the Act - Following decision of CIT v. Yokogawa India Ltd. [2011 (8) TMI 845 - Karnataka High Court] - Decided in favour of assessee.
Depreciation on fixed asset - Relevant bills not produced - Held that:- assessee was unable to file any evidence in support of acquisition of fixed assets during previous years relevant to assessment years 2001-02 to 2004-05. Disallowance of claim of depreciation for the impugned assessment year has been done only with respect to the written down value of those assets on which assessee could not produce bills for acquisition in the earlier years - Decided against assessee.
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2013 (8) TMI 479 - ITAT KOLKATA
TDS u/s 194H - commission paid to the directors - Disallowance for remuneration/commission - Held that:- no tax was deducted at source from remuneration/commission paid to the director - No valid material showed on record to derive from judgment for CIT(A) - No distinguishable facts could also be pointed out - No Infirmity in order of CIT(A) - Following decision of Jahangir Biri Factory (P) Ltd vs D.C.I.T. [2009 (3) TMI 215 - ITAT CALCUTTA-C] - Decided in favour of Assessee.
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2013 (8) TMI 478 - ITAT MUMBAI
Indexed costs of acquisition - family arrangement - sibling of the assessee relinquished their rights. - CIT(A) held year 1981-82 as base year for A.Y. 2006-07 as against F.Y. 2003-04 determined by the Assessing Officer. - Held that:- The Ld. DR could not place on record any contradictory material in support of his contention that the indexation should be with reference to the financial year in which property devolved on assessee by virtue of family arrangement - No reason to interfere with the order passed by the CIT(A) - the indexed cost of acquisition of such capital asset has to be computed with reference to the year in which the previous owner first held the asset. - Following decision of DCIT vs Manjula Shah [2009 (10) TMI 646 - ITAT MUMBAI] - Decided in favour of Assessee.
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2013 (8) TMI 477 - ITAT CHENNAI
Exemption u/s 54F - Sale consideration - purchase of five flats - claim of deduction as one house property - Held that:- None of the authorities below has doubted the eligibility of the assessee for claiming an exemption under section 54F of the Act. Their only qualm is that assessee had preferred such claim for all the five flats whereas according to them, such exemption could only be founded to a single flat - A residential house in the context could not be construed as a singular - It is not necessary that all residential units should have a single door number allotted to it - However, this alone was not the reason why assessee was held to be eligible for claiming of exemption under section 54F of the Act - Following decision of CIT v. Smt. K.G. Rukminiamma [2010 (8) TMI 482 - Karnataka High Court] and Dr. Smt. P.K. Vasanthi Rangarajan v. CIT [2012 (7) TMI 563 - MADRAS HIGH COURT] - assessee was eligible for claiming exemption under section 54F of the Act on the five flats received by her in lieu of the land she had parted with. - Decided in favour of assessee.
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2013 (8) TMI 476 - ITAT CHANDIGARH
Interest on outstanding loans - Accrual of interest on NPA - Scheduled Bank - Special provisions u/s 43D - Held that:- loans were advanced since 1999 and they had become NPAs against which suits for recovery were filed by the assessee in various Courts. In view of the assessee having neither received the loans or part thereof nor any interest therefrom, no interest was provided in the books of account as the recovery of the loans itself had become difficult. Admittedly, the assessee was following mercantile system of accounting under which income is to be recognized when the same accrues irrespective of the fact whether the same is received or not. However, in respect of the interest due on NPAs special provisions are provided under section 43D of the Act, which is non obstante clause and in case of NPAs i.e. the debts recovery of which had become bad, interest is to be provided on this recovery, i.e. the year in which it is actually received by the institution or the bank or other body or when it is charged to the Profit & Loss Account whichever is earlier.
The provisions of section 43D of the Act override other provisions of the Act and said provisions are applicable in the case of assessee, being Scheduled Bank. Once the loans had become NPAs and the assessee had opted to account for the interest on such NPAs only on recovery of the same, the law recognizes such treatment of interest on NPAs as valid in view of the provisions of section 43D of the Act - No addition - Decided against Revenue.
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