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Showing 161 to 180 of 16576 Records
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2021 (12) TMI 1369
TDS u/s 194H - Demand u/s 201(1) and 201(1A) - TDS recovery mechanism regarding the alleged commission paid to pre-paid mobile distributors in its telecom services - as vehemently contended that there exists no principal to agent relation between the assessee and its distributors giving rise to commission element qua the pre-paid recharge coupons - HELD THAT:- We find no merit in the assessee's instant former substantive grievance since the CIT(A) has duly taken note of hon’ble jurisdictional high court decision in M/s. Vodafone Essar South Ltd. [2013 (10) TMI 934 - ANDHRA PRADESH HIGH COURT] - Their lordships have upheld the departmental stand pertaining to applicability of section 194H involving identical prepaid recharge coupons issued to the distributors. It further appears that the said assessee was the assessee’s group concern only. We thus adopt their lordships foregoing detailed reasoning mutatis mutandis and reject the instant former substantive grievance.
As the legislature has itself incorporated section 201(1) first proviso in the Act vide Finance Act, 2012 w.e.f. 1.7.2012 that an assessee shall not be treated to be the assessee in default for having not deducted TDS provided it furnishes the accountant’s certificate qua its payee to have furnished the latter return of income u/s. 139; taking into account such sum for computation followed by payment of due taxes thereupon; respectively.
Case law CIT Vs. Ansal Landmark Township [2015 (9) TMI 79 - DELHI HIGH COURT] holds the foregoing proviso r.w.s. 40(a)(ia) second proviso (inserted in the Act vide Finance Act, 2012 w.e.f. 1.4.2013) to be carrying retrospective effect being curative in nature. We thus restore the instant issue for the Assessing Officer’s factual verification in the very terms. This identical first and foremost substantive grievance is partly accepted for statistical purposes.
Applicability of “royalty” for the purpose of TDS deduction on domestic auto-roaming charges paid to other telecom operators - applicability of the impugned royalty provision 9(1)(vi) - HELD THAT:- We find no merit in the Revenue’s instant stand. It is made clear that section 194J (1)(c) of the Act stipulating TDS deduction on royalty makes it clear in Explanation (ba) that “royalty” shall have the same meaning as in Explanation 2 clause (i) to (vi) of sub-section (1) of section 9 of the Act.
There is no indication in the Assessing Officer’s TDS recovery order or in the CIT(A)’s findings as to whether the assessee's impugned payments made to the spectrum holder(s); as the case may be, satisfies any of the foregoing clauses defining royalty or not. All the assessees have availed is a standard facility without any customisation. The Revenue’s case is that the assessee fails to dispute the Govt. of India’s action collecting royalty qua spectrum (supra). We observe that the said stipulation between assessee's payee(s) and Govt. to this effect does not in any way mean that it itself has made any royalty payment to very payee(s) for utilizing/uplinking the spectrum in question.
The Revenue’s last argument invoking TDS mechanism going by the assessee suo moto deduction in Assessment Years 2015-16 and 2016-17 (supra) does not ipso facto attract the impugned statutory provisions. We lastly conclude that the specific definition prescribed by the legislature in the Act regarding payment of royalty would override the agreements and corresponding terminology employed between the Govt. of India, Telecom Department with the corresponding spectrum allottees going by stricter interpretation as per hon'ble apex court’s decision in Commissioner of Customs Vs. Dilip Kumar & Co. [2018 (7) TMI 1826 - SUPREME COURT] We accordingly proceed to decide the assessee's instant identical latter substantive ground in both these appeals against the department.
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2021 (12) TMI 1368
Deduction u/s 80IC - whether the process undertaken by the assessee in its industrial unit at Parwanoo amounted to ‘manufacture’ or ‘production’ of the Anchors so as to qualify the requirements? - HELD THAT:- Petitioner seeking permission to withdraw the appeal. Ordered accordingly.
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2021 (12) TMI 1367
Maintainability of appeal - hearing of the matter - HELD THAT:- As the hearing has commenced before the Ld. NCLT, Cuttack Bench and as has been listed as part-heard on 06.01.2022, this instant Appeal is not maintainable and the Appeal deserves to be dismissed.
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2021 (12) TMI 1366
Permission for withdrawal of appeal - monetary amount involved in the appeal - amount involved in this appeal is much less than the threshold limit of Rs. 50 lakhs - circular dated 22.08.2019 issued by Ministry of Finance, Department of Revenue, Central Board of Indirect Taxes and Customs (Judicial Cell) - HELD THAT:- The appeal is accordingly, dismissed as withdrawn.
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2021 (12) TMI 1365
Rejection of proposal for a One Time Settlement (OTS) - HELD THAT:- The petitioner has not placed on record any policy in terms of which its OTS claim was to be considered by the Bank. At Mr. Chandhiok’s request, two weeks’ time is granted for filing of additional affidavit in this regard.
List on 18.01.2022.
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2021 (12) TMI 1364
Seeking grant of Bail - Smuggling of Gold - statement under Section 108 of Customs Act - it is submitted that as per statement of the petitioners under Section 108 Customs Act, they are habitual in same transaction - HELD THAT:- Taking into account the facts and circumstances of the case and without expressing any opinion on the merits of the case, this court deems it just and proper to enlarge the petitioners on bail.
It is ordered that the accused-petitioners Shivram Meena S/o Shri Vishram Meena and GyanchandMeena Son Of Nandlal Meena shall be enlarged on bail provided each of them furnishes a personal bond in the sum of Rs.50,000/- with two sureties of Rs.25,000/- each to the satisfaction of the learned trial Judge for their appearance before the court concerned on all the dates of hearing as and when called upon to do so - Bail application allowed.
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2021 (12) TMI 1363
Right to claim refund of Additional Duty of Customs paid under Section 3(5) of the Customs Tariff Act - TIME LIMITATION - can Section 27 of the Customs Act, 1962 nor Notification No.93/2008 dated 1-8-2008, impose limitation on the right to claim refund? - limitation of one year for claiming refund of Additional Duty of Customs paid under Section 3(5) of the Customs Tariff Act would commence from the date of sale or from payment of duty contrary to the Notification No.93/2008 dated 1-8-2008 issued in exercise of powers under Section 25(1) of the Customs Act 1962?
HELD THAT:- The issue involved herein is no more res integra in view of the order passed by this Court in THE COMMISSIONER OF CUSTOMS, BANGALORE VERSUS M/S. MOLEX INDIA PVT. LTD. [2021 (10) TMI 342 - KARNATAKA HIGH COURT], whereby the Co-ordinate Bench of this Court (Hon’ble SSJ was a member) has categorically observed that neither Section 27 of the Act of 1962 nor a notification under Section 25(1), such as the amended notification No.93/2008-Cus can be used to impose a limitation period and the right to claim refund.
In the present case, the contention of the Revenue that the period of one year during the relevant period is the period of limitation prescribed under Section 27 of the Act of 1962 for refund of claim as per Notification No.102/2007 is wholly untenable for the reason that the refund of SAD would be claimed by the assessee subsequent to completion of the assessment. In many cases, as the SAD would be refundable only on subsequent sale, which is not in the control of the assessee.
It is, thus, clear that no limitation period can possibly be imposed for advancing a refund claim, since SAD levied under Section 3(5) of the Customs Tariff Act, 1975 is refundable only on completion of subsequent sale. Given the vagaries of the market, the importer has limited control over the sale when it would be complete.
Appeal dismissed - decided against Revenue.
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2021 (12) TMI 1362
Violation of principles of natural justice - cross-examination of witnesses denied upon whose statement respondent authority has relied before passing the impugned adjudication order which is adverse to the interest of the petitioner - HELD THAT:- Considering the submissions of the parties and in view of the fact that factual and legal questions are involved in this writ petition and this is not such type of a case which can be thrown out at motion stage, this writ petition is entertained and respondents are directed to file affidavit-in-opposition within 17th January, 2022, petitioner to file reply thereto, if any, within 24th January, 2022. List this matter on 25th January, 2022 for final hearing.
Respondents shall not take coercive action on the basis of impugned adjudication order till 1st February, 2022 or until further orders whichever is earlier.
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2021 (12) TMI 1361
Approval of resolution plan - section 30(6) read with section 31 and section 60(5) of the Insolvency and Bankruptcy Code, 2016 read with Regulation 39(4) of The Insolvency and Bankruptcy Board of India (Insolvency Process of Corporate Persons) Regulations, 2016 - HELD THAT:- The Resolution Plan filed with the Application meets the requirements of Section 30(2) of IB Code, 2016 and Regulations 37, 38, 38(1A) and 39 (4) of IBBI (CIRP) Regulations, 2016. An affidavit under section 29A has also been filed by the Resolution Applicant. The Resolution Professional has also certified that the Resolution Plan' approved by the CoC does not contravene any of the provisions of the law for the time being in force. The Compliance Certificate is placed on record. The Resolution Plan' has been approved by the CoC with a 95.23% voting share. It is satisfying that Resolution Plan is in compliance with all relevant provisions of the IB Code 2016, and CIRP Regulations.
The Resolution Plan is hereby approved, which shall be binding on the Corporate Debtor and its employees, members, creditors, guarantors, and other stakeholders involved in the Resolution Plan including Resolution Applicant - Application allowed.
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2021 (12) TMI 1360
Taxable income to tax u/s 44BB v/s Section 44DA read with section 9(l)(vii) - services provided by the assessee in respect of core pressure & wellbore studies, post stack inversion studies, data processing & maintenance services etc which are prima facie backend activities in the nature of technical services - Assessee argued as Activities are in the nature of ‘mining or like project’ and thus not in the nature of ‘fees for technical services. The services provided by the appellant, were used in the exploration/exploitation of mineral oils - HELD THAT:- As respectfully relying upon the decision of Hon’ble Supreme Court in the case of ONGC [2015 (7) TMI 91 - SUPREME COURT] it is held that the receipts of the Assessee on account of post-stack inversion study, core pressure and wellbore study, data processing and maintenance services were taxable under section 44 BB of the Act.
Contention of the revenue that the amounts have to be taxable u/s 44DA - We hold that to invoke the provisions of Section 44DA, the revenue has to prove that the receipts are indeed or in the nature of FTS taxable u/s 9(1)(vii).
Reimbursement of equipment lost in hole - revenue or capital receipt - HELD THAT:- As the name signifies lost in hole means destruction and loss of capital assets like drilling equipment which are provided by the assessee to oil exploration and. production companies. Therefore, the revenue received on account of loss of equipment does not form income in the hands of the assessee rather it is a mere reimbursement of the cost of equipment destroyed in the process of oil extraction.
As reliance on the decision of the Hon’ble Uttarakhand High Court in the own case of the assessee [2009 (7) TMI 51 - UTTARAKHAND HIGH COURT] wherein the Hon’ble Court held that the receipts on account of equipment lost in hole being in the nature of capital receipts cannot, be included in the revenues chargeable to lax u/s 44BB - We find considerable cogency in assessee's submission as above. Hence, we hold that the Assessing Officer has erred in including the sum received by the assessee as reimbursements for determining the taxable income of the assessee. - Decided against revenue.
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2021 (12) TMI 1359
Income accrued In India - amount derived by the Appellant on account of distribution revenue from Turner International India Private Limited (‘TIIPL’) as royalty under Section 9(i)(vi) of the Act and also as per the provisions of India-USA Double Taxation Avoidance Agreement (‘DTAA’) - Permanent Establishment (‘PE’) - HELD THAT:- Issue decided in favour of assessee as relying on own case [2020 (10) TMI 245 - ITAT DELHI]
Non allowance of the credit of taxes deducted at source wrongly withheld on revenue not chargeable to tax in India as per Section 9 of the Act - HELD THAT:- Undisputed fact is that the revenue derived from Apalya Technologies Pvt. Ltd. and Parragon Publishing India Pvt. Ltd. are not taxable in India as per Section 9 of the Act. It is also not in dispute that since the income does not form part of the total income of the assessee the credit of TDS was denied. The credit was also denied in A.Y.2013-14 as mentioned elsewhere. The assessee can claim the credit of TDS in the country in which the related income is offered to tax. We, therefore, do not find any reason to interfere with the findings of the DRP. Ground No.7 is accordingly dismissed.
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2021 (12) TMI 1358
Seeking amendment in final resolution plan - seeking to uncaps the CIRP costs on conditions stated therein - seeking to reduce term of the plan from 180 days to 90 days - HELD THAT:- The CIRP period will come to end on 06.01.2022 and a decision on the resolution plans will have to be taken first by the CoC and, thereafter by this Adjudicating Authority.
The ends of justice will be met if it is directed that the applicant herein to place the affidavits at Page Nos. 290 to 298 alongwith the covering letter addressed to the sole member of the CoC for consideration. Since disturb level playing field is not intended to be disturbed, the other resolution applicants whose plans are also being considered will also be permitted to place any modification in their submitted resolution plan before the CoC for its consideration. Such modifications shall be communicated to the CoC, no later than 48 hours from now.
Application disposed off.
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2021 (12) TMI 1357
Rectification of mistake - error apparent on the face of record - typographical error - HELD THAT:- In the 2nd last line of the 2nd paragraph of the first page of the order, the expression “the question jurisdiction on each raised by the petitioner before the Arbitral Tribunal” shall stand deleted and be placed with the expression “the petitioner shall participate in arbitration”.
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2021 (12) TMI 1356
Reference of disputes and differences to Arbitration under five several contracts - reference made by the Facilitation Council, MSME, under Sections 18(2) and 18(3) of the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act) - applicability of MSMED Act to the Works Contract - legality of clubbing of five different contracts into one reference for adjudication - HELD THAT:- This Court is of the view that without prejudice to any of the rights and contentions of the writ petitioner, the question jurisdiction on each raised by the petitioner before the Arbitral Tribunal - The Tribunal shall decide on its jurisdiction on inter alia the questions raised by the writ petitioner before entering into other questions.
Petition disposed off.
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2021 (12) TMI 1355
Seeking approval of the Resolution Plan - section 30(6) read with section 31(1) of the Insolvency and Bankruptcy Code, 2016 and regulation 39(4) of the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 - HELD THAT:- The Resolution Plan has been approved with 99.10% voting share. As per the CoC, the plan meets the requirement of being viable and feasible for revival of the Corporate Debtor. By and large, all the compliances have been done by the Resolution Professional and the Resolution Applicant for making the plan effective after approval by this Bench - On perusal of the documents on record, it is satisfying that the Resolution Plan is in accordance with sections 30 and 31 of the IBC and also complies with regulations 38 and 39 of the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016.
As far as the question of granting time to comply with the statutory obligations or seeking approvals from authorities is concerned, the Resolution Applicant is directed to do so within one year from the date of this order, as prescribed under section 31(4) of the Code - In case of non-compliance of this order or withdrawal of Resolution Plan, the payments already made by the Resolution Applicant shall be liable for forfeiture.
The Resolution Plan is approved - application allowed.
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2021 (12) TMI 1354
Disallowance u/s 40A(2) - payment to related party - Addition made as Ms. Anjali Lall does not possess the required qualification to undertake the job of interior decoration, repair and maintenance and secondly, the payment is unreasonable and excessive - HELD THAT:- Expression “the Assessing Officer is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities” as used in section 40A(2) of the Act makes it abundantly clear that the opinion of the Assessing Officer cannot be formed in vacuum and without any cogent evidence. It is the Assessing Officer who has to establish on record that the payment made to the related party is unreasonable and excessive having regard to the market value of the goods, services or facilities for which payment is made. In the facts of the present case, admittedly, except stating that the related party is not technically qualified to undertake the work and the payment made is unreasonable and excessive, the Assessing Officer has not brought any material on record to demonstrate that the payment made is excessive and unreasonable having regard to the market value of the services for which such payment was made. Thus, the disallowance made under section 40A(2) without being back by cogent evidence and purely on conjectures and surmises, cannot be sustained. Accordingly, we delete the disallowance made - Decided in favour of assessee.
TDS u/s 195 - disallowance u/s 40(a)(i) - failure to withhold tax at source on payment made to various persons/entities outside India towards professional/technical fee - HELD THAT:- Payments made to non-resident attorneys cannot be regarded as FTS under section 9(1)(vii) of the Act. Further, a conjoint reading of section 40(a)(i) and 40(a)(ia) brings out a clear distinction between FTS and fees for professional services. Though, section 40(a)(ia) encompasses, both, FTS and fees for professional services, however, section 40(a)(i) is applicable only in case of failure to deduct tax on payments made for FTS. As rightly submitted by learned counsel for the assessee, this could be for the reason that payment of legal/professional fee to a non-resident does not accrue or arise in India or is not deemed to accrue or arise in India as per section 5 and section 9 of the Act. It is relevant to observe, in the case of NQA Quality Systems Registrar Ltd. Vs. DCIT [2004 (12) TMI 323 - ITAT DELHI-F] the coordinate Bench has held that professional services are a category distinct from technical services.
Thus we hold that the payments made to non-resident attorneys being not in the nature of FTS, there was no obligation on the assessee to deduct tax at source.
Payments made to foreign attorneys are not chargeable to tax under the provisions of the Act, in terms of section 195 of the Act. Therefore, the assessee was not required to withhold tax on the payments made. Accordingly, we delete the disallowance made under section 40(a)(i) of the Act. - Decided in favour of assessee.
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2021 (12) TMI 1353
Attachment of Bank Accounts - fraudulent availment of ITC - non-application of mind - Section 83 of CGST Act - HELD THAT:- The order impugned herein, wherein, the learned single Judge while setting aside the order of attachment, has observed that the 'opinion' of the second appellant is far more cryptic revealing total non-application of mind and merely repeating what the first appellant has stated in the request for sanction and accordingly, allowed the writ petition and directed the appellants to complete the process of assessment within a period of six weeks.
This court, without going into the merits of the order impugned herein, finds it appropriate to modify the order passed by the learned single judge, only in respect of the direction issued to the appellants. Accordingly, the order impugned herein is modified to the effect that the appellants are at liberty to issue show cause notice to the first respondent within a period of four weeks from the date of receipt of a copy of this judgement and on receipt of the same, the first respondent shall file their objections and documentary evidence, if any, within a period of two weeks thereafter.
Appeal disposed off.
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2021 (12) TMI 1352
TP adjustment pertaining to the Manufacturing segment -Treating subsidy received by the assessee as a revenue receipt or capital receipt - operating revenue for determining the ALP of the Manufacturing segment - Manufacturing segment which comprises of Import of raw material, Sale of manufactured goods, Payment of technical license fees/Royalty and Payment of one time technology transfer fees - HELD THAT:- The assessee received subsidy under Package Scheme of Incentives (PSI) given by the Government of Maharashtra which was treated as an item of revenue receipt and at the same time, it was also included in the operating revenues for determining the ALP of the Manufacturing segment. In a note given to its balance sheet.
Primary contention of the assessee is that the subsidy is in the nature of capital receipt and hence, should be excluded - When we apply such a test on the facts and circumstances of the case, it demonstrably emerges that the purpose of subsidy is industrial growth; it is linked with the setting up of industrial units; and the amount of subsidy is linked with the amount of investment made in the eligible unit. Simply because the subsidy has been disbursed in the form of refund of VAT and CST, it will not alter the purpose of granting the subsidy, which is nothing but establishment of new industrial units in less developed areas of the State. The authorities below have been swayed by the fact that the subsidy was granted post commencement and is in the nature of refund of VAT and CST and overlooked the purpose of its granting, which is nothing but momentum in industrial pace in less developed parts of the State. Testing the factual panorama on the touchstone of the ratio laid down by the Hon’ble Supreme Court in the above referred cases, we are of the considered opinion that the subsidy of Rs.89.73 crore is a capital receipt and not chargeable to tax.
It is relevant to mention that we are concerned with the A.Y. 2014-15. The Finance Act, 2015 has inserted clause (xviii) to section 2(24) w.e.f. 01-04-2016 providing that the assistance in the form of subsidy or grant of cash incentives etc., other than the subsidy which has been taken into consideration in determining the actual cost of the asset in terms of Explanation 10 to section 43(1), shall be considered as an item of income chargeable to tax. Since the amended provision of section 2(24)(xviii) is not applicable to the year under consideration, the sequitur is that the subsidy received by the assessee would not form part of its total income. We, therefore, overturn the impugned order and direct to treat the subsidy as an item of capital receipt not chargeable to tax.
In view of the fact that the subsidy has been held to be a capital receipt, obviously, it cannot form part of operating revenue of the Manufacturing segment of the assessee company for the purpose of determining the ALP under the TNMM.
AR contended that in the hue of the amendment to section 2(24) of the Act, the assessee offered the subsidy as a revenue receipt chargeable to tax for the A.Y. 2016-17 and also claimed it as operating revenue for the purpose of the ALP determination, which issue is sub judice before the Tribunal. We desist from commenting on the treatment of subsidy as an item of operating revenue or otherwise because it is not required for the disposal of the present appeal, for which the subsidy has been held to be a non-operating revenue on the ground that it is a capital receipt and does not form part of the total income of the assessee.
To sum up, the subsidy is capital receipt not chargeable to tax and at the same time it will not be included in the operating revenue for determining the ALP of the Manufacturing segment - we hold that the profit margins of the comparables cannot be reduced by the difference in the amount of Custom Duty because there is no evidence of any difference in the Custom Duty rates paid by the assessee as well as the comparables. Respectfully following the precedent, we uphold the impugned order on this score. This ground fails.
Comparable selection - Inclusion of Bharat Earth Movers Limited and JCB India Limited in the list of comparables - TPO included Bharat Earth Movers Limited in the list of comparables despite the assessee’s objections - AR submitted that the comparable was there in the immediately preceding assessment year and the Tribunal has directed to exclude the same from the list of comparables. Relevant discussion has been made in para 7 of the Tribunal order. After considering the relevant material, the Tribunal has directed to exclude Bharat Earth Movers Limited. The ld. DR could not controvert the argument of the assessee. Respectfully following the precedent, we order to exclude this company from the list of comparables. This part of the ground is, therefore, allowed.
Next comparable assailed by the assessee is JCB India Limited, which was included by the TPO in the list of comparables - No relief was allowed by the DRP. The ld. AR fairly submitted that the inclusion of JCB India Limited in the list of comparables was challenged by the assessee for the immediately preceding assessment year as well but the Tribunal has upheld the decision of the authorities below in this regard. We have perused the order passed by the Tribunal on this issue for the immediately preceding assessment year. Relevant discussion has been made in para 8 of the order. After elaborate analysis of the factual and legal position, the Tribunal has finally held that JCB India Limited was rightly included in the list of comparables. Following the same view, we countenance the inclusion of this company in the list of comparables. This part of the ground is, therefore, dismissed.
Transfer pricing adjustment on entity level as against the proportionate adjustment - AR submitted that similar issue was raised in the assessee’s appeal for the immediately preceding assessment year and the Tribunal was pleased to direct the AO/TPO to restrict the transfer pricing adjustment to the extent of international transactions under the Manufacturing segment. The ld. DR also fairly admitted the position. Respectfully following the precedent, we direct the AO/TPO to restrict the transfer pricing adjustment to the extent of international transactions under the Manufacturing segment.
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2021 (12) TMI 1351
Assessment u/s 153A - Addition u/s 68 - unexplained share capital received from 24 persons - neither the creditworthiness of these creditors nor the genuineness of transactions were established as submitted by the AO in Assessment Order and Remand Report - CIT(A) was convinced that the assessee has successfully discharge the onus cast upon it by provisions of Section 68 of the Act and deleted the addition - HELD THAT:- On these facts ratio laid down by the Hon'ble High Court of Delhi in the case of Kabul Chawla .[2015 (9) TMI 80 - DELHI HIGH COURT] which was followed in the case of Meeta Gutgutia [2017 (5) TMI 1224 - DELHI HIGH COURT] squarely apply where.has held that where no incriminating material was unearthed to show that there was violation by the assessee to disclose income/additions made by the Assessing Officer was not justified. - Decided in favour of assessee.
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2021 (12) TMI 1350
Assessment order u/s 143(3) making additions under Section 69-A - petitioner has filed appeal before the CIT-A against addition and said appeal is presently pending for hearing - meanwhile demand notices were issued to the petitioner which were followed by garnishee notices - HELD THAT:- After hearing learned counsel for the parties and on due consideration, we are of the view that it would meet the ends of justice if a direction is issued to the Appellate Authority i.e., respondent No.1 to take up the stay petition of the petitioner dated 05.04.2021 and pass appropriate orders thereon in accordance with law. We are of the further opinion that the said stay petition should be decided within a period of six weeks from the date of receipt of a copy of this order. Till such time, the demand pursuant to assessment order dated 21.12.2019 shall remain stayed.
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