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Showing 121 to 140 of 1076 Records
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2014 (10) TMI 964
Application before appropriate forum - Held that:- Petitioner does not press this application and seeks permission to withdraw the same, as his client intends to file an appropriate application before the appropriate forum. If such application is filed before the appropriate forum, the same may be taken into consideration and decided in accordance with law
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2014 (10) TMI 963
Tax the capital gain as short term capital gain - whether the tax rate specified in section 112 for long term capital gain was not applicable to the capital gain computed under section 50 in respect of long term asset? - Held that:- n the present case, it is not in dispute that the office premises which was sold by the assessee was a part of the business asset and section 50 is applicable as assessee had claimed depreciation on the same. We are unable to accept the submission of the Ld. Counsel that in the case of Ace Builders Pvt. Ltd. (2005 (3) TMI 36 - BOMBAY High Court) the Hon’ble High Court has held that even capital gain is computed in the manner prescribed u/s.50 in that case also, the same is to be treated as long term capital gain.
It is clear from the language used by the legislature that if the long term capital gain is computed then it will suffer the tax @20% as against the normal rate of income tax. Moreover, in the Ace Builders Pvt. Ltd., (supra) their Lordships have explained that if the capital gain is computed as provided u/s.50 then the capital gains tax will be charged as if such capital gain has arisen out of short term capital asset. We have to interpret the judgement or decision as a whole and we cannot interpret in the piecemeal to understand the ratio decidendi.
Counsel has also relied on the decision in the case of M/s. P.D. Kunte & Co. (Regd.) (2005 (3) TMI 36 - BOMBAY High Court). It is true that in said case the assessee had taken Ground No.2 which is analogous to the plea of the assessee. But on perusal of the said order, we find that the said ground remained to be adjudicated and there is no decision on this issue. We are not therefore inclined to rely upon the decision in the case of M/s. P.D. Kunte & Co. (Regd.) (Supra). We accordingly approve the interpretation made by the Ld.CIT(A) of section 50 and section 112 and confirm the order on this issue before us. Accordingly, the grounds taken by the assessee are dismissed.
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2014 (10) TMI 962
Addition on suspicion based on the statement of a third party - Held that:- We have found that share application money of ₹ 50 lakhs was invested by M/s. Moderate Credit Corporation Ltd., a listed company, which fact is evident from the record. This investment is found to have been made through account payee cheque and has been refunded in the similar manner when the project was dropped. The statement of Shri Aseem Gupta recorded behind the back of the assessee cannot be relied on in the case of a third party. His statement does not specifically mention the name of the assessee-company. There is no iota of evidence to suggest that either directly or indirectly any cash or unaccounted money of the assessee had flown to the share applicant company or vice versa. The share applicant has confirmed its deposit. Therefore, any share application money when the applicant is identified and has confirmed its deposit with the assessee-company, cannot be added in the assessee-company’s hand, as per the settled position of the law. - Decided against revenue.
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2014 (10) TMI 961
Deduction claimed u/s. 80IA in respect of profit earned from the project Godawari Lift Irrigation Scheme developed by the Govt. of Andhra Pradesh - Held that:- As decided in assessee's own case [2014 (9) TMI 1065 - ITAT PUNE] we are not inclined to interfere with the finding of CIT(A) who has deleted the disallowances u/s.80IA of the Act in respect of profit earned from the project Godawari Lift Irrigation Scheme and Guthpa Lift Irrigation Scheme respectively.
Disallowance of the warranty provision - Held that:- CIT(A) has rightly decided the issue in the light of judgement of the Hon’ble Supreme Court in the case of Rotork Control India P. Ltd. (2009 (5) TMI 16 - SUPREME COURT OF INDIA). We uphold the same.
Disallowance u/s.40(a)(ia) - assessee has not deducted tax at source on payment of commission to the Non-executive Directors - Held that:- The issue before us is with regard to commission paid to director. The issue has to be looked into its facts and circumstances which needs deep probe into the matter. So, in the interest of justice, we restore this issue to the Assessing Officer with a direction to decide the same as per fact and law after providing due opportunity of being heard to the assessee.
Computation of Book profit u/s.115JB - Held that:- We are not inclined to interfere with the finding of CIT(A) who has upheld the addition made by the Assessing Officer to the Book Profit as defined under Explanation to section 115JB. We uphold the same.
Medical expenses reimbursed to employees and payment of Fringe Benefit Tax - Held that:- Since the CBDT has issued clarification that reimbursement of medical expenses up to ₹ 15,000/- is taxable as a fringe benefit in the hands of the employer, the Assessing Officer following the Circular has rightly treated the reimbursement of medical expenses to employees and non-working directors of the company as a fringe benefit under section 115 WB(2)(E) of the Act. Accordingly, the action of the Assessing Officer on this ground is upheld.
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2014 (10) TMI 960
Trading addition - Held that:- There is no dispute to the fact that the A.O. has not pointed out any defect in the books of account and the books of account have not been rejected by invoking provisions of Section 145(3) of the Act. Even if this ground has not been raised before the learned CIT(A) or even before us in the grounds of appeal, the fact remains that no books of account have been rejected by invoking the provisions of Section 145(3) of the Act and therefore, the trading results will be deemed to have been accepted by the A.O. Therefore, no additions can be made by the A.O. - Decided in favour of assessee.
Addition u/s 68 - establish genuineness of the loans - Held that:- Though the creditor does not appear to be taxable during the years of the savings, and therefore by perusing the earnings and expenses of the family, and assessee not being the income tax assessee, thus of the view that the creditor being the real sister of the assessee must have given ₹ 1,00,000/- loan by depositing cash in her bank account. The assessee had proved the identity, creditworthiness and genuineness of the transaction and therefore, he has discharged his onus and therefore, no addition is called for and the addition sustained by learned CIT(A) is directed to be deleted along with the interest of ₹ 11,047/-. The order of learned CIT(A) is reversed and the addition of ₹ 1,11,047/- is directed to be deleted. Thus, the ground no. 2 raised by the assessee is allowed.
Addition of cash credit in the name of Smt. Salochna Devi - Held that:- The creditor Smt. Salochna Devi is the mother of the assessee who is the widow lady of around 67 years has furnished the affidavit confirming the loan given to the assessee by making a cash deposit of ₹ 60,000/-. She is not an income tax assessee. She has stated in her statement before the A.O. of doing book binding business from where she earns ₹ 70,000/- to 80,000/- per annum, is not disputed. The said cash was given to the assessee, who deposited the same in the creditor’s account from where cheque has been taken. She has also stated that she is living with her son. In this circumstances and facts of the case, I am of the view that the assessee has proved the identity, creditworthiness and genuineness of the transaction and accordingly no addition of ₹ 60,000/- is called for alongwith the interest of ₹ 7,200/-. - Decided in favour of assessee.
Addition of expenses on account of low withdrawals - Held that:- A.O. has estimated the expenses on account of withdrawals at ₹ 12,000/- per month, but no basis of the same has been given while estimating the same. Though, the assessee is living in his own house in a small town which has been explained by the assessee and in the circumstances and facts of the case, no addition is warranted. Accordingly, the order of the learned CIT(A) on this very ground is reversed and the A.O. is directed to delete the addition so made and sustained by learned CIT(A). Also as the additions made by the A.O. on account of withdrawals have been deleted hereinabove, there is no question of setting off the same against the cash credit. - Decided in favour of assessee.
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2014 (10) TMI 959
Whether supply of ready mix concrete and carrying out the ancillary and incidental activities of pouring, pumping and laying of concrete would call for service tax liability or not? - Held that: - Tribunal in the case of GMK Concrete Mixing Pvt. Ltd. v. CST, Delhi [2011 (11) TMI 425 - CESTAT, NEW DELHI] has held that the entire exercise is sale of ready mix concrete and there is no service element involved so as to create service tax liability against the assessee - appeal allowed - decided in favor of appellant.
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2014 (10) TMI 958
Auction for sale - properties owned by a company under liquidation and there has been price fixation by the Company Court - Held that: - There can be no speck of doubt that the properties of a company under liquidation when sold, there has to be a proper auction, a fair one. It must fetch the maximum price. It takes care of statutory dues, dues of the workmen and the creditors. It has its own public character. In any case, it cannot be allowed to be sold for a song. The estimated price given by Gitco is more than ₹ 66 crores for 113 plots, which are free.
We direct M/s Star and Associates to deposit a sum of ₹ 20 crores by the end of November 2014 and another ₹ 40 crores by 15-3-2015 before the Registry of this Court - the rest of the plots in respect of which there is an order of status quo by this Court or which are sub judice before the appellate court on the company side before the High Court, needless to say, shall be dealt with at the subsequent date - SLP allowed in part.
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2014 (10) TMI 957
Taxability relating to conversion of unpaid interest on SBI loan into a “fresh term loan” - disallowance invoking Explanation 3A of sec. 43B - Held that:- We notice that the ld. AR has furnished many factual details, which have not been examined at all by the tax authorities. Further, the ld. AR has rightly pointed out that Explanation 3A shall apply only for those payments for which the deduction had been allowed in assessment year 1996-97 and in the earlier years on accrual basis. However, since the Ld A.R has furnished various factual details and since they have not been examined by the tax authorities, we are of the view that this issue requires fresh consideration at the end of the AO. Accordingly, we set aside the order of the ld. CIT(A) on this issue and restore the same to the file of AO for his fresh examination in the light of discussion made supra. The AO is directed to examine the factual details furnished by the ld. AR and take appropriate decision in accordance with law after providing necessary opportunity of being heard to the assessee.
Rejection of claim of set off of brought forward unabsorbed depreciation claimed against “Short Term Capital Gain” and “Long Term Capital Gain” - AO disallowed the said claim on the reasoning that unabsorbed depreciation, though gets merged with the current depreciation, can be carried forward indefinitely and can be set off only against “profit and gains” and not against any other income - Held that:- Unabsorbed depreciation can be set off against the “Business Income” or against the income derived from any “other source”, on the reasoning that the treatment given to current year depreciation would equally apply to brought forward depreciation also. Thus we set aside the order of ld. CIT(A) and direct the AO to allow the set off of unabsorbed depreciation against capital gains. See Suresh Industries (P) Ltd V/s ACIT (2012 (11) TMI 674 - ITAT MUMBAI) and DCIT V/s Akay Flavours and Aromatics (P) Ltd (2010 (9) TMI 1123 - ITAT COCHIN) - Decided in favour of assessee.
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2014 (10) TMI 956
Admission of additional documents - pleas of the respondent not to take the documents on record and not to consider them - Held that:- Considering the documents it is apparent that there cannot be doubt about the genuineness of these documents. The plea of the respondent is that the documents are not relevant. However, this plea of the respondent cannot be accepted. The contention of the applicant is that the properties which have been attached had not been acquired from the proceeds of crime. In these circumstances, the copies of bank accounts and income-tax returns will be relevant and it cannot be inferred at this stage that the applicant has not been able to discharge his burden. The contents of the documents and whether they establish that the applicant did not have proceeds of crime can be inferred only after the documents are taken on record and considered in view of the pleas and contentions of the applicant.
Therefore, the pleas of the respondent not to take the documents on record and not to consider them cannot be accepted. For the foregoing reasons the application is allowed and additional documents are taken on record subject to payment of ₹ 2,000/- as cost to the learned counsel for the respondent.
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2014 (10) TMI 955
Non allowance of loss on sale of securities - Adhoc disallowance of expenses - Held that:- The Tribunal had decided the issue against the assessee while deciding the appeal for the earlier years as held there is no dispute that provisions of section 73 Explanation can be applied where a company deals in purchase and sale of shares of other companies. However there are two exceptions provided in the said Explanation and undisputedly the assessee does not fall -within the ambit of those two exceptions. The only argument of the learned counsel for the assessee is that such purchase and sale of securities were effected only for testing the working of the website to ensure that the same functions within any glitches. We do not find merit in such submission since the assessee is continuously carrying on the purchase and sale of shares as informed to us by the learned counsel for the assessee. Further, the assessee itself is showing such transactions as part of its business activity. Therefore, there is no reason to take any contrary view. In our view, the CIT(A) has rightly upheld the order of the Assessing Officer treating the same as speculation loss - Decided against assessee
Disallowance of bad debts - Held that:- We find that after 01.04. 1989,the only requirement of writing off of bad debt is entries in the books of accounts by the assessee concerned. It has not to prove the justification of its action i.e.writing off,once it makes necessary entries in the P & L account. The Hon’ble Apex Court in the matter of T.R.F. Ltd. (2010 (2) TMI 211 - SUPREME COURT) had laid down the above basic principle and same is being followed by various Courts. Respectfully following the same we decide ground no.2 in favour of the assessee.
Depreciation on BSE Membership Card - Held that:- We find that in the matter of Techno Shares and Stocks Ltd [2010 (9) TMI 6 - SUPREME COURT OF INDIA] has held - “on a consideration of the BSE rules, that the right of membership was a "business or commercial right" and could be said to be owned by the assessee and used for business purposes in terms of section 32(1)(ii). The right of membership, which included the right of nomination, was a "licence" or "akin to a licence" which was one of the items which fell in section 32(1)(ii). The right to participate in the market had an economic and money value. It was an expense incurred by the assessee which satisfied the test of being a "licence" or "any other business or commercial right of similar nature" in terms of section 32(1)(ii).” - Decided against AO
Addition of expenditure attributable to speculative business - AO had made a disallowance of ₹ 5 lakhs, that was reduced to ₹ 2.5 lakhs by the FAA - Held that:- While deciding the issue in the appeal filed by the assessee,we have held that the Tribunal had in the earlier years decided the issue of speculation loss against the assessee. But, reduction in disallowance made by the FAA was upheld by the Tribunal. Following the order of the Tribunal for the year 2003-04,we uphold the order of the FAA and decide ground no.2 against the AO.
Disallowance of client Assistance Charges(CAC) paid to ICICI Bank - AO had disallowance as he was of the opinion that the payment was made to a party covered by the provisions of section 40(A)(2)(b) - Held that:- We find that he has not given the basis as how he arrived at the conclusion that ICICI Bank,the receiver of the payment,was a party covered by the provisions of the said section.For invoking the provisions of 40A regarding related party,it has to be proved that the assessee had incurred an expenditure by making payment to the person referred to in clause (b). We find that the AO had presumed that payment was made to related party.He has also not explained as how the payment was excess or unreasonable.For arriving at such a conclusion,he should have compared the case with similar type of cases and proved that the payment was above normal practice of the trade.He has not made any attempt to prove the fact.In these circumstances,in our opinion,the order of the AO was rightly reversed by the FAA.
There is no yardstick mentioned by the AG or CIT(A) as to what is fair market value of the goods, services or facilities for which the payment is made. Further nothing has been brought on record to show that the expenditure in question was excessive or unreasonable considering legitimate needs of the business or profession of the assessee or benefit by or accruing to the assessee. The fact that the assessee has its own infrastructure or that it has incurred huge advertisement expenses cannot be a ground to make the disallowance. In fact, infrastructure pointed out by the Assessing Officer is only with regard to facilities of trading. The Assessing Officer has totally ignored the fact that the customers were procured only through network of ICICI Bank Ltd., across the country. The rendering of services by ICICI Bank Ltd., which have already set out above, contributed to the business of the assessee and payment of commission, in our view was fully justified. - Decided in favour of assessee.
Disallowance of expenses on software development - Held that:- We find that as far as incurring of expenditure is concerned the AO has doubted it. He was of the opinion that same was of capital nature.From the records it is clear that the assessee had made payment to HCL Comnet Ltd. and CWIP amounting to ₹ 27,72,471/-,for development of software programme, but the project could not materialise,that no depreciation was allowed with regard to the payment in question. We are of the opinion that the expenditure incurred by the assessee was incurred for carrying out the business for the year under consideration and it suffered a loss in the transaction. - Decided in favour of assessee.
Penalty u/s 271(1)(c) - assessee had treated share transaction under the business head,whereas the AO was of the opinion that same were covered by the provisions of section 73 - Held that:- Penalty as per the provisions of section 271(1)(c) is not automatic.Addition or disallowance during the assessment proceedings or their confirmation in appellate proceedings do not and should not result in invoking the penal provisions in a mechanical manner.Before imposing penalty for furnishing of inaccurate particulars it has to be seen that the claim made by the assessee was false or not bona fide. In the matter before us,the assessee had treated share transaction under the business head,whereas the AO was of the opinion that same were covered by the provisions of section 73.Thus,there were two possible views about the transaction in question and the assessee had followed one of the views.It is said that if a wrong claim is made by an assesse and explanation is offered then in the absence of a finding that the assessee had failed to prove such explanation was bona fide, no penalty can be imposed. - Decided in favour of assessee.
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2014 (10) TMI 954
Application for Speaking to the Minutes - Held that:- Paragraph 5 of the said order shall now read as under :
“5. From the aforestated facts it is established that an amount of ₹ 18,38,970.52 is due and payable by the Company to the Petitioner along with interest as claimed. The Company has failed and neglected to respond to the statutory notice and has also not made any payments to the Petitioner after receipt of the said notice. The Petition sought to be served on the Company is returned with the remark that the addressee is not found. Since the Petition was sought to be served at the registered address of the Company, which address on that day is shown as the registered office of the Company in the records of the Registrar of Companies, the Company Petition is deemed to have been served on the Company though the same has been returned with the remark that the addressee is not found. In view thereof all that is stated in the Company Petition has remained uncontroverted. I am therefore satisfied that the Company is unable to pay its debts and is commercially insolvent."
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2014 (10) TMI 953
Addition u/s 14A - Expenses in relation to income not forming part of total income – Held that:- Question of law answered in favour of the Assessee and against the Revenue. There is no dispute in that regard because the Tribunal has relied upon a judgment of this Court in the case of Godrej & Boyce Mfg. Co. Ltd. V/s. Deputy Commissioner of Income Tax reported in (2010 (8) TMI 77 - BOMBAY HIGH COURT). Thereafter the matter was sent back to the Assessing Officer and who has applying ratio of the Division Bench, granted the claim of the Assessee.
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2014 (10) TMI 952
ALV determination - Income from house property - municipal valuation disregarded - Held that:- Annual Letting Value has to be determined and in terms of section 23(1)(a) with reference to the municipal rateable value. If that is found to be vitiated and for the reasons set out in our judgment, then, alone a departure can be made. The Tribunal has held that there were no circumstances or factors brought on record which would enable the Assessing Officer to determine the Annual Letting Value by disregarding the municipal valuation. He could not have assumed any other value at which the property would be let from year to year. In such circumstances and his assumption being contrary to law, the Tribunal was justified in allowing the Assessee's Appeal.
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2014 (10) TMI 951
Addition u/s.14A - rule 8D applicability - computation of claim - Held that:- As gone though the order of the authorities below. It is the settled proposition of law that the application of Rule 8D is mandatory on and from A.Y. 2008- 09. We find that the disallowance has been computed as per the formula given under Rule 8D. We, therefore, do not find any reason to interfere with the findings of the ld. CIT(A). Ground no. 1 with its sub-ground is dismissed.
Addition of cash expenses - addition u/s 40A - Held that:- It is not in dispute that the assessee has incurred expenditure amounting to ₹ 2,39,73,409/- in cash. It is also an undisputed fact that the auditors have qualified in their report that amount of ₹ 9.18 lacs have been paid in cash in violation of the provisions of section 40A(3) of the Act. Although the same was claimed to be allowable as per Rule 6DD, however, no details have been furnished, neither before the Revenue authorities nor before us. Therefore, the expenditure of ₹ 9.18 lacs are clearly disallowable, as per the qualification of the Auditors. That leaves us with a balance disallowance of ₹ 38.76 lacs. In our considered opinion, 50% out of this should meet the ends of justice, therefore, in addition to the disallowance of ₹ 9.18 lacs, we direct the A.O. to restrict the disallowance out of the balance expenditure at ₹ 19.38 lacs meaning thereby that the total disallowance should be restricted to ₹ 28.56 lacs. Ground no. 2 with its sub ground is partly allowed.
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2014 (10) TMI 950
Scheme of Amalgamation - Held that:- All the observations and comments by the Regional Director made in respect of the Scheme in question have been explained and/or met with and/or do not sustain. The necessary report is produced by the official liquidator. Furthermore, from the material on record and perusal of the Scheme, the Scheme appears to be fair and reasonable and is not in violation of any provisions of law and is not contrary to public policy. None of the parties concerned have come forward to oppose the Scheme except as mentioned above. All requisite statutory compliances are fulfilled.
This court is accordingly satisfied that the Scheme of Arrangement in the nature of Amalgamation amongst the petitioner companies deserve to be granted. Accordingly, prayer in paragraph-21(A) both in Company Petition Nos. 152 of 2014 and 153 of 2014, as well as prayer in paragraph-17(a) in Company Petition No. 154 of 2014 are hereby granted.
It is further ordered that as required under Section 396-A of the Companies Act, 1956, the transferor companies shall not dispose of or destroy its books of accounts and other connected papers without the prior consent of the Central Government and shall preserve the same.
All the three petitions are allowed and disposed of accordingly.
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2014 (10) TMI 949
Payment for royalty - nature of expenditure - revenue or capital - Held that:- Considering the fact that identical issue in 2005-06, 2006-07 & 2008-09 assessment years have been followed and the years under consideration are intervening years and noting that there is no change in facts, circumstances or position of law as held the royalty payment is determined annually on the basis of quantity and value of production, the expenditure so incurred by the assessee is essentially recurring and revenue in nature. However, the AO has treated 25% of such payment as capital in nature. The expenditure so claimed is charged on the products manufactured by the assessee company and the same is not incurred for acquiring a process or design or technology which can be utilized by the assessee for years to come so as to categorize such expenditure, as capital in nature. Nothing was brought on record by the learned DR to controvert the findings of the CIT(A). We therefore do not find any reason to interfere in the order of CIT(A) for allowing the entire payment of royalty as revenue expenditure. Appeals of the Revenue are dismissed.
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2014 (10) TMI 948
Rejection of Settlement Commission Application - Section 127B of the Customs Act - requirement that the application must be accompanied by a Bill of Entry or Shipping Bill in respect of which a show cause notice has been issued to the applicant - the decision in the case of Rohit Sakuja Versus Union of India [2014 (4) TMI 1182 - DELHI HIGH COURT] contested, where it was held that A facial reading of the proviso (a) to Section 127B informs the Court that the applicant has to necessarily file either the Bill of Entry or the Shipping Bill in respect of the export or import of the goods (which are the subject matter of the application), with regard to which a show cause notice has been issued to him by the appropriate officer - Held that: - the decision in the above case upheld - appeal dismissed - decided against appellant.
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2014 (10) TMI 947
Appointment as Chief Medical Officer - selection process - cancellation of appointments challenged after 27 years - Held that:- The selection process took place in the year 1986. Appointment orders were issued in the year 1987, but were also cancelled vide orders dated June 22, 1987. The respondents before us did not chalelnge these cancelleation orders till the year 1996, i.e. for a period of 9 years. It means that they had accepted the cancellation of their appointments. They woke up in the year 1996 only after finding that some other persons whose appointment orders were also cancelled got the relief. By that time, nine years had passed. The earlier judgment had granted the relief to the parties before the Court. It would also be pertinent to highlight that these respondents have not joined the service nor working like the employees who succeeded in earlier case before the Tribunal. As of today, 27 years have passed after the issuance of cancellation orders. Therefore, not only there was unexplained delay and laches in filing the claim petition after period of 9 years, it would be totally unjust to direct the appointment to give them the appointment as of today, i.e. after a period of 27 years when most of these respondents would be almost 50 years of age or above.
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2014 (10) TMI 946
CENVAT credit - input services - outward transportation service from the place of removal - Held that: - The definition of inputs service during the relevant period included in its ambit the transportation from the place of removal - In this regard Karnataka High Court judgment in the case of CCE & ST, LTU Bangalore Vs. ABB Ltd. [2011 (3) TMI 248 - KARNATAKA HIGH COURT] held that transportation charges incurred by manufacturer for clearance for final product from place of removal were included in definition of input service - appeal allowed - decided in favor of appellant.
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2014 (10) TMI 945
Revision u/s 264 - Commissioner of Income Tax power to entertain the application for revision under section 264 from an Intimation u/s 143(1) - Held that:- In the present facts taking into account the conduct of the Commissioner of Income Tax in ignoring the binding decision of this Court, we do not consider it appropriate to consider the submissions made on behalf of the revenue when the order of the Commissioner is ex facie in defiance of the decisions rendered by this Court in Anderson Marine Ltd. (2003 (12) TMI 47 - BOMBAY High Court) wherein this Court had held that Section 264 would be applicable even in respect of Intimation issued under Section 143(1) of the Act post 1 June 1999. In an appropriate case, we would consider the submission on behalf of the revenue.
Accordingly, the impugned order dated 20 April 2006 is set aside and the application is restored to the Commissioner of Income Tax with a direction to pass an appropriate order in accordance with law. Commissioner of Income Tax directed to dispose of the petitioner's application under section 264 of the Act as expeditiously as possible and preferably within 8-weeks from today.
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