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Showing 61 to 80 of 1445 Records
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2024 (3) TMI 1385
Challenge to impugned notice - levy of penalty - unauthorized collection of tax - HELD THAT:- As per the details furnished by the petitioner and by taking out the figures of tax effect in regard to credit notes issued during the years in question regarding the sales return as well as credit notes given on account of trade discount, the respondent issued the impugned show cause notice to the petitioner.
This Court further observes that the impugned show cause notice was communicated to the petitioner and the reply thereto was also submitted by the petitioner, but as yet, no final order in the matter has been passed by the respondent on count of the fact that the interim order dated 22.04.1998 passed by this Hon’ble Court is operating in this case - This Court also observes that as per the settled proposition of law, normally, the writ Court should not interfere at the stage of issuance of show cause notice by the authorities concerned, as in such cases, the parties concerned get ample opportunity to put forth their legal issues before the authorities concerned.
This Court disposes of the present petition, with liberty to the petitioner to avail the remedy as available to it under the law and to raise all the legal issues as raised herein and other issues, if any, before the appropriate forum, strictly in accordance with law, after passing of the final order by the respondent in the matter.
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2024 (3) TMI 1384
Existence of PE - whether the assessee had Permanent Establishment (‘PE’) in India ? - HELD THAT:- Since in the present case, the functional analysis carried out in step 1 by the Tribunal was already answered in negative that the India entity did not perform any additional functions that would lead to creation of a PE in India, the remuneration for the same would ideally be NIL. Thus, the amount of profits already offered to taxes by the Indian entity should be considered to be at arm's length and no further attribution is required.
Since the AE has already been remunerated at arm’s length, no further profit ought to be attributed to the alleged PE of the Assessee in India, this view is supported by the decision of Morgan Stanly and Company [2007 (7) TMI 201 - SUPREME COUR]]
The Hon'ble Delhi High Court in the case of Adobe Systems Incorporated [2016 (5) TMI 728 - DELHI HIGH COURT] held that in situation where the dependent agent has not been remunerated at arm’s length, adjustment can only be made in the transfer pricing assessment of the dependent agent and there could be no addition in the hands of the non-resident (which is held to have a PE in India in the form of the dependent agent).
Thus we hold that no business profits are attributable to the alleged PE of the Assessee in India. Decided in favour of assessee.
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2024 (3) TMI 1383
Validity of assessment order passed on objections being pending consideration before the Dispute Resolution Panel - HELD THAT:- The Income-tax Act enables a person who receives a draft assessment order u/s 144C to file objections before the Dispute Resolution Panel. In the case at hand, the petitioner filed objections and there is evidence that the Dispute Resolution Panel received such objections on 12.01.2024. The impugned order is clearly subsequent thereto.
As contended by respondents, the petitioner should have informed the National Faceless Assessment Unit that objections were filed before the Dispute Resolution Panel. Nonetheless, the issuance of the impugned assessment order while the objections of the petitioner are pending before the Dispute Resolution Panel causes great prejudice to the petitioner especially in view of the fact that the transfer pricing officer had directed variations in the income. For such reason, the impugned order calls for interference.
Therefore, the impugned assessment order is quashed and, as a consequence, the assessing officer is directed to await the decision of the Dispute Resolution Panel before issuing a fresh assessment order.
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2024 (3) TMI 1382
TP Adjustment - comparable selection - exclusion of Larsen and Toubro Infotech Ltd. [“L&T”], Wipro Technology Service Ltd. [“Wipro”] and Zylog Systems Ltd. [“Zylog”] from the list of comparables - HELD THAT:- Insofar as the case of L&T is concerned, it appears to have been urged before the ITAT that although financials of that entity were on record, it was impossible to bifurcate and identify the revenues that may have been obtained by it from software development services and products with precision.
Rejection of Wipro as a comparable and in respect of which the ITAT found that Wipro had rendered similar services pertaining to software development and consequently was functionally similar to the assessee. However, the aforesaid comparable came to be excluded in light of the tainted and controlled transactions which it had with Citi Technology Services Ltd.
Zylog is concerned, the reasoning for its exclusion is identical to that ascribed to L&T Ltd. In that view of the matter and on an overall conspectus of the aforesaid, we find no infirmity in the view as expressed by the ITAT. No substantial question of law.
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2024 (3) TMI 1381
Disallowance u/s 90 for Foreign Tax Credit - non filing Form No. 67 - assessee argued that the provisions of the India-US DTAA support their claim for the foreign tax credit - HELD THAT:- We agree with the contentions put forth by assessee and hold that Rule 128(9) of the Rules does not provide for disallowance of FTC in case of delay in filing Form No.67, filing of Form No.67 is not mandatory but a directory requirement and DTAA overrides the provisions of the Act and Rules cannot be contrary to the Act.
AR submitted that the case is already covered in favour of the assessee and filed the orders of Tribunal wherein the Tribunal gave decision in favour of assessee, including the order [2023 (10) TMI 86 - ITAT HYDERABAD] - The said decisions are not stayed or over-ruled by any of the higher Judicial Forums.
As respectfully following the decision of the Ashish Agarwal [2023 (10) TMI 86 - ITAT HYDERABAD] allow the appeal. Thus, the appeal of the assessee is allowed.
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2024 (3) TMI 1380
Revenue earned from Indian payer on account of drilling rights on hire (equipment rental) under contracts - taxation u/s 9(1)(vi) read with section 115A of the Act and Article 12 of the India-Malayasia DTAA or deemed profit rate of 10% u/s 44BB - HELD THAT:- As would be manifest from clause (iv-a) of the Act, although the “right to use any industrial, commercial or scientific equipment” is otherwise covered under the expression “royalty”, it makes a clear exclusion in respect of amounts which would be referable to Section 44BB of the Act.
No justification to interfere with the view as taken by the ITAT.
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2024 (3) TMI 1379
TP Adjustment - Royalty and payment of Technical fee paid by the respondent/assessee to its Associated Enterprise (AE) - HELD THAT:- Appellant, on instructions apprises us that although the aspect of royalty may have constituted the subject matter of the AYs as noticed by us hereinabove, the issue of technical know-how fee did not form the subject matter of consideration in AYs 2011-12, 2012-13 and 2013-14.
We note that undisputedly in AY 2010-11, both aspects were duly examined by the DRP. The direction as framed by the DRP in terms of the statutory regime which prevails would clearly bind the Assessing Officer.
No justification to entertain the instant appeal. Consequently, we see no reason to interfere with the impugned order of the ITAT. The present appeal stands dismissed on the aforesaid terms.
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2024 (3) TMI 1378
Delay of 1367 days in filing the appeal - Eligible reasons of delay given or not? - HELD THAT:- We find there is no acceptable explanation for the inordinate delay except for stating certain administrative grounds. On perusal of the order passed by the learned Tribunal, impugned in this appeal, we find that the learned Tribunal has taken note of the decision of Almatis Alumina Pvt. Ltd [2022 (2) TMI 1063 - CALCUTTA HIGH COURT]
The correctness of the said decision was challenged by the revenue before this Court and in the case of Almatis Alumina Pvt. Ltd. [2022 (2) TMI 1063 - CALCUTTA HIGH COURT] the appeal filed by the Department was dismissed. Apart from that, with regard to the Indian Transfer Pricing guidelines issued by the Institute of Chartered Accountants of India vide guidance note on report u/s 92E by ICAI and transfer pricing guidelines issued by OECD the issue was whether it prohibits a foreign associate enterprise (AE) to be a tested party. This issue was considered by this Court in the case of ITC Infotech India Ltd., [2024 (1) TMI 1400 - CALCUTTA HIGH COURT].
Thus, we find that apart from there being no explanation for the inordinate delay, the legal issue raised in this appeal is squarely covered in the aformentioned decisions
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2024 (3) TMI 1377
Penalty u/s 271AAA - assessee declared the surrendered amount under the head "additional income" which was accepted by the Revenue - HELD THAT:- We prima facie find merit in the submission of revenue that a mere surrender of income would not absolve the assessee from the levy of penalty.
We are thus of the considered opinion that the appeal merits further consideration and it shall consequently stand admitted on the aforenoted question of law.
Let the appeal be called again on 24.07.2024.
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2024 (3) TMI 1376
Validity of re-assessment proceedings u/s 148 as time barred - HELD THAT:- Having considered the submissions of learned counsel for the parties and particularly taking into consideration that the reassessment is initiated vide impugned notice issued on 26.03.2023 in relation to Assessment Year 2012-13 and also the provisions contained in Section 149(1)(b) of the Act, as amended vide Finance Act, 2021, pre-existing provisions of Section 149 and Section 153C as also the orders passed by the different High Courts, the petitioner has made out a strong prima-facie case.
In that view of the matter, it is ordered that though reassessment proceedings may go on, final order shall not be passed without the leave of the Court.
The respondents are granted four weeks’ time to file reply.
List this case on 07.05.2024 for final disposal with other connected matters.
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2024 (3) TMI 1375
Validity of re-assessment proceedings as time barred - HELD THAT:- Having considered the submissions of learned counsel for the parties and particularly taking into consideration that the reassessment is initiated vide impugned notice issued on 26.03.2023 in relation to Assessment Year 2012-13 and also the provisions contained in Section 149(1)(b) of the Act, as amended vide Finance Act, 2021, pre-existing provisions of Section 149 and Section 153C as also the orders passed by the different High Courts, the petitioner has made out a strong prima-facie case.
It is ordered that though reassessment proceedings may go on, final order shall not be passed without the leave of the Court. The respondents are granted four weeks’ time to file reply.
List this case after four weeks for final disposal.
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2024 (3) TMI 1374
Provisional release of the seized goods - inaction on the part of the respondent customs authority concerned in considering and disposing the application of the petitioner for release of the detained xerox machine in question on provisional basis - HELD THAT:- This writ petition being WPA 6206 of 2024 is disposed of by directing the respondent Commissioner of Customs (Port)/the authority concerned to intimate the petitioner on or before 27th March, 2024 the additional customs duty which shall be paid by the petitioner, within seven days from the date of receipt of such intimation to be issued by the respondent customs authority.
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2024 (3) TMI 1373
Maintainability of appeal before the CIT (A) against letter issued by AO - in the Miscellaneous Application, assessee has pleaded that assessee cannot be asked to do impossible - HELD THAT:- In this case, assessee had filed an appeal before the ld. CIT(A) against recovery letter issued by Assessing Officer(AO). Ld. CIT (A) dismissed the appeal of the assessee stating that the letter issued by AO is not an appealable order as per section 246A of the Act.
Aggrieved by the order of the ld. CIT(A), assessee filed appeal before this Tribunal. Before the Tribunal, assessee admitted that assessee had filed appeal before the ld. CIT(A) against the letter issued by AO. There are specific orders mentioned in section 246A against which appeal can be filed before the ld. CIT(A). There is no provision in the Income Tax Act to file an appeal against a letter issued by AO. Therefore, ITAT vide order dated 05.04.2023 upheld the order of ld. CIT(A).
No specific apparent mistake has been pointed out by the assessee in the impugned order. In these facts and circumstances of the case, the Miscellaneous Application of the assessee is dismissed.
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2024 (3) TMI 1372
Exemption under Notification 5/2006- CE dated 01.03.2006 (Sl.No.21) - gold bars manufactured in the factory at Hutti - classification of gold bar manufactured in their factory under tariff heading 71081200 of the First Schedule to the Central Excise tariff Act, 1985 - recovery of Excise duty with penalty - invocation of Extended period of limitation.
Admissibility of the benefit of the Notification No.5/2006-CE dated 01.03.2006 - HELD THAT:- A simple reading of the said Notification conveys that the primary gold when converted with the aid of power from any form of gold, be eligible to ‘Nil’ rate of duty of goods falling under Chapter 71 of Central Excise Tariff Act, 1985. There is no dispute about the end product i.e., ‘dore bar’ manufactured by the appellant satisfy the meaning of ‘primary gold’ provided in the said Notification. The entry 21 of the said Notification No.05/2006-CE dt. 01.03.2006 has been amended by Notification No.25/201-CE dated 01.04.2011 and the Appellant discharged duty from 01.04.2011 to 31.12.2011, which has been appropriated in the impugned order.
The dispute centres around the interpretation of the expression conversion ‘from any form of gold’ to primary gold i.e., ‘dore bars’ as was in the said entry at Sl. No.21 till 31.03.2011. In the impugned order, it is observed that ‘any form of gold’ would mean gold in its original form, that is, it should be in existence before its conversion into another form of gold i.e. ‘dore bars’. Applying the common parlance test, the Revenue has argued that the old ornaments of gold, articles of gold, other primary form of gold like ornaments, pellets, etc., is ‘gold in any form’. It is an age-old practice to make new ornaments from old/broken ornaments; and for making new ornaments, old articles are melted to obtain specific form of gold or that the same could be used again in making new articles. In the said process, existing gold is transformed into another form by melting the same and there is no emergence of altogether a new item on conversion. Thus, it is the intention of the Government to exempt primary gold obtained/ manufactured from any other existing form of gold. The Commissioner has held that any form of gold refers to metallic gold.
Whether extracting gold from the stage of ‘anode slime’ satisfy the expression conversion of any form of gold to primary gold of the Notification No.06/2000-C.E. dated 01.03.2000? - HELD THAT:- The starting point in the present case is gold ore, which has been subjected to both physical and chemical processes to obtain gold concentrate, which is later subjected to further process by which gold powder is obtained. The said gold powder taken to the melting refinery section and mixing the concentrate with other chemicals and heating up to 1200 centigrade, impurities are separated and gold is obtained in the form of buttons after cooling. The purity of gold buttons smelted from table concentrate and that from the gold precipitate powder vary in quality. The buttons obtained from both the processes are melted together to eliminate further impurities and homogenous gold dore bars are manufactured having gold content of 90-92% purity - The objective is to consider exemption of final products, i.e., primary gold in the form of dore bars resulted from conversion of any form of gold, which in the present case is the gold powder/concentrate. Consequently, the Appellant are eligible to the benefit of the Sl. No. 21 of the exemption Notification No. 05/2006 CE dt.01.3.2006 till it has been amended by Notification 25/2011CE dt.24.3.2011.
Since the appellants succeeds on merits, the other issues of limitation and imposition of penalty becomes academic, hence not dealt with.
The impugned order set aside - appeal allowed.
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2024 (3) TMI 1371
Taxing the recovery in respect of bad debts written off by banks - addition u/s 41(4) - assessee argued that since the bad debts written off were adjusted against the provisions created under section 36(1)(viia), and no deduction was claimed u/s 36(1)(vii), the recovery should not be taxed - HELD THAT:- Where a deduction has not been allowed in respect of bad debts written off under the 2nd stream, the question of charging the recovery effected out of such bad debts written off to tax will not arise. In the third situation discussed in the chart, when the assessee does not make any provision as per RBI Guidelines, then it cannot claim any deductions under section 36(1)(viia) of the Act and it can only claim deduction u/s 36(1)(vii) of the Act, if there is any recovery, it can be charged to tax u/s 41(4) of the Act.
Therefore, the proposed addition of recovery of bad debts by the AO is not proper and observation of CIT (A) is also not correct, the revenue has to appreciate the actual claim of deductions made by the assessee under various provisions exclusively enacted for the purpose of banking companies has to be read along with the tax computation submitted by the assessee and not express their opinion without properly verifying the impact in the tax computation. It may look double deduction while reading the provisions in isolation. Accordingly, the grounds raised by the assessee is allowed.
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2024 (3) TMI 1370
Rejection of application for approval u/s 80G(5) - application being made under a different Clause (ii) of First Proviso of Section 80G(5) by mistake instead of u/s 80G(5)(iii) - HELD THAT:- As we find merit in the case of the assessee. Procedure is the handmade of justice. Therefore, rejection of grant under Section 80G merely on procedural lapse by making application under Section 80G(5)(ii) inadvertently instead of u/s 80G(5)(iii) on the part of the assessee is not acceptable. Further that having regard to the identical facts and circumstances of the matter in the case relied upon by the A.R. we set-aside the issue to the file of the Ld. CIT(E) with a direction upon him to treat the said application under Section 80G(5)(iii) of the Act and to pass orders strictly in accordance with law. Appeal of the assessee is allowed for statistical purposes.
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2024 (3) TMI 1369
India taxable in India - receipts from offshore supplies to THDC India Ltd ("THDC") - Existence of Business Connection and Permanent Establishment (PE) in India - Income deemed to accrue or arise in India - Proof of business connection in India during the subject assessment year - DRP/AO attributing 100% profits from offshore supplies made to THDC to the alleged business connection/ PE.
HELD THAT:- AO had made the addition towards offshore supplies by observing that there is a business connection of the assessee in India u/s 9(1)(i) of the Act. We are unable to comprehend ourselves to accept to this proposition in as much as title transfer in respect of equipment supplied by the assessee to THDC on an offshore basis happened outside India. Payments are made in foreign currency and that too are received by the assessee outside India. The law is very well settled by the decision of Ishikawajma-Harima Heavy Industries Ltd [2007 (1) TMI 91 - SUPREME COURT] that if the sale is concluded outside India and the property in goods is passed outside India; the payment of consideration is received outside India; no activity in relation to such offshore supply is conducted in India, then income from such offshore supplies cannot be made liable to tax in India as assessee does not constitute “Business Connection” in India. It is also pertinent to note that under the Contract No.3 which is in dispute before us, Offshore Supply under THDC Contract, supply of plant and equipment was to take place on "FOB" basis.
Title to and property in the goods shipped by the assessee stood transferred at the port of shipment and the event of sale clearly took place outside the territory of India. In these facts, the income arising out of such sale cannot be said to have accrued or arisen in India. The accrual of income derived from offshore supplies cannot be attributed to any operation in India and therefore, no income can be deemed to accrue or arise in India.
Fixed Place PE of the assessee in India - AO had merely reproduced the observations made in the assessment order of some other assessee with respect to PGCIL contract without appreciating the fact that the receipts were earned by the assessee herein from THDC and NHPC project during the year under consideration. There was no contract undertaken by the assessee with PGCIL and no amounts were received from PGCIL by the assessee. This clearly proves the complete non-application of mind on the part of the ld. AO. Either way, it is trite law that onus is on the revenue to establish that there exists a PE of the foreign entity in India, which has not been discharged by the revenue in the instant case.
Construction PE of the assessee in India under the provisions of Article 5(2) of India-France DTAA - As all the findings of Delhi Tribunal in GE Group company cases relied upon by the ld. AO cannot be made applicable to the facts of the assessee herein. It is also relevant to understand that Contract No. 03 between THDC and assessee is in dispute before us with regard to offshore supply. Admittedly THDC is a Government of India Undertaking, which had split the contracts. Splitting of contracts is not done at the behest of the assessee. The case laws relied upon hereinabove for non-existence of Fixed Place PE in India would apply for nonexistence of Construction PE also. Hence we have no hesitation to hold that the assessee does not have a Construction PE in India and accordingly no income earned by the assessee from operations and activities undertaken outside India could be brought to tax in India in terms of Article 5(2) of India-France DTAA.
We hold that there cannot be attribution of Business Connection u/s 9(1)(i) of the Act, alleged PE (both Fixed Place and Construction PE) and applicability of provisions of section 44BBB of the Act in respect of receipts for offshore supplies in the instant case.
Application of Section 44BBB of the Income-tax Act - We find that since the amount under consideration pertain to offshore supply of plant and equipment, for which sale was completed outside India and title to the goods was transferred outside India without any role of the alleged PE in India, the provisions of section 44BBB of the Act per se cannot be made applicable in the instant case.
We find that reliance in this regard was placed on case of DDIT vs Mitsui & Co Ltd [2020 (2) TMI 1053 - ITAT DELHI] Even otherwise, we have already held that that there is no PE of the assessee in India and hence as per Article 7 read with Protocol thereon of India UK DTAA, income earned out of offshore supplies cannot be brought to tax in India in the hands of the assessee. Here the treaty provisions are also beneficial to the assessee herein and hence on this count also, there cannot be taxability of income in respect of offshore receipts in the hands of the assessee.
Since we have already held that there is no PE of the assessee in India, the other argument advanced by the ld. AR that there would be no attribution of profits in view of operational or net loss at global level, need not be gone into as adjudication of the same would become merely academic in nature.
Thus, we hold that assessee was engaged in offshore supply of plant and equipment pursuant to contract with THDC and that the said contract was not artificially split for gaining any tax advantage as alleged by the revenue; there is no business connection of the assessee in India; there does not exist Fixed Place PE or Construction PE of the assessee in India and provisions of section 44BBB of the Act are not applicable in the instant case. Hence we hold that the addition made by the ld. AO by bringing to tax receipts from offshore supply is hereby directed to be deleted. Decided in favour of assessee.
Disallowance of deduction of claim on account of write off of duty draw back - HELD THAT:- We find that the assessee had duly written off the amount of duty drawback receivable after knowing the fact that JDGFT had rejected the claim of the assessee that Chamera project does not qualify as a mega power project under the foreign trade policy. In our considered opinion, the said claim is made by the assessee in its normal course of business and accordingly be eligible for deduction as a trading loss u/s 28 of the Act itself. In the instant case, the assessee had duly proved that the said duty drawback is irrecoverable from the Govt. Similar issue arose before the coordinate bench of this Tribunal in the case of NEC Technologies India Pvt Ltd [2023 (6) TMI 1322 - ITAT DELHI] as inclined to hold that the input cost is revenue in nature and accordingly service tax paid on such revenue cost is also eligible to claim as revenue expenditure u/s. 37(1). The said loss is also allowable as business loss u/s 37(1) of the Act.
Levy of interest u/s 234B - AR argued that interest u/s 234B of the Act is not chargeable on the ground that the buyer has deducted tax at source and remitted to the account of the Central Govt in accordance with the proviso to section 209(1)(d) of the Act and hence there would be no liability for the assessee to pay advance tax - HELD THAT:- In the present case, THDC, who is buyer of offshore supplies made by the assessee which has been brought to tax by the ld AO in the final assessment order, had duly deducted tax at source before making the said payment. Hence, it was submitted that there was no default on the part of the assessee in payment of advance tax - interest u/s 234B of the Act is not chargeable in the instant case. Accordingly, the Ground raised by the assessee is allowed.
Chargeability of interest u/s 234C - The law is well settled that the said interest should be charged only on the returned income and not on the assessed income. Accordingly, the Ground raised by the assessee is allowed.
Chargeability of interest u/s 234D of the Act, which is consequential in nature.
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2024 (3) TMI 1368
Classification of "fish meal" - it was held by High Court that 'This Court is unable to sustain the order of learned Single Judge holding that the petitioners supply fish meal as a finished product and therefore, they fall under Sl. No. 102 of Notification No. 2 of 2017 within Tariff Heading 2301. The term “including” in the description of goods cannot be interpreted to include even fish meal in powder form, when it is not sold as aquatic feed.'
HELD THAT:- Issue notice to the respondents.
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2024 (3) TMI 1367
Availment of excess amount of ineligible CENVAT Credit which was distributed by its ISD - contravention of the provisions of Rules 3 and 7 of the CCR, 2004 - wilful suppression of facts or not - whether the disallowance of credit in the hands of the appellant which was distributed by their Head Quarter at Thane as Input service distributor is correct or otherwise? - HELD THAT:- It is found that exactly the same issue in case of Appellant’s Tiruchirapalli unit has been decided by the Chennai Bench vide Final Order [2023 (2) TMI 7 - CESTAT CHENNAI], observing that 'There is also nothing brought out on record if the appellant, being a recipient unit, had any role or influence in the manner of distribution so that a case of wilful suppression with an intention to evade payment of duty, etc., could be justified. When the appellant took consistent stand inter alia that its Head office-ISD unit was regularly filing its ER-1 return, that the service provider unit at Head Office had Service Tax liability every year, which was paid in cash and that the entire tax liability was paid in cash every year rather than paying through the CENVAT Credit, the lower authorities have not denied anywhere the above facts.'
In view of the decision of the Chennai Bench which squarely is applicable to the facts of present case, there are no merits in the impugned order - Appeal allowed.
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2024 (3) TMI 1366
Grant of interim bail - Seeking grant of Bail - Money Laundering - existence of proof of identification of proceeds of crime or not - absence of transcripts to alleged transfer of Rs. 30 crores - Section 45 of PMLA - HELD THAT:- Re-list in the week commencing 29.04.2024.
The petitioner – Abhishek Boinpally is directed to be released on interim bail for a period of five weeks from the date of release on terms and conditions to be fixed by the trial court. In addition to the terms and conditions fixed by the trial court, the petitioner – Abhishek Boinpally shall provide one mobile number to the Officer(s) of the Enforcement Directorate, who will be entitled to get in touch with the petitioner – Abhishek Boinpally and to ascertain his whereabouts. The petitioner – Abhishek Boinpally will surrender his passport to the trial court, and would not leave the National Capital Region without permission of the trial Court. The petitioner – Abhishek Boinpally will be entitled to travel his home town, that is, Hyderabad.
SLP disposed off.
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