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Showing 181 to 200 of 1706 Records
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2016 (7) TMI 1532
Penalty u/s 271(1)(c) - Addition by estimating GP - HELD THAT:- This addition has been made by making estimate at all stages. The AO had estimated GP at 9% as against GP of 5.8% disclosed by the assessee; CIT(A) adopted 8% whereas the Tribunal has reduced it to 7%. The assessee is aggrieved with the fact that the detailed working submitted by it pointing out fallacies in the estimation done at various stages has been ignored . It is further noted by us that in any case, the addition has been made on estimate basis only. Concealment of income has not been proved by the AO while levying penalty. We do not find any justification to levy penalty on the addition which has been made on estimate basis and also keeping in view the fact that there is no uniformity even on the estimation. Thus, penalty levied on this addition is directed to be deleted.
Addition u/s 69C - low household withdrawal for personal expenses - HELD THAT:- Addition has been reduced by the Tribunal to ₹ 40,000. In this case also, we find that pure guess work has been adopted by the lower authorities in making this addition. Thus, we do not find justification for levy of penalty in this case also and penalty levied on the same is directed to be deleted.
Addition of interest - assessee had used borrowed funds for giving loan to M/s Shreekar Polyester Pvt Ltd and though assessee had earned interest income from the said party, the same was not assessable as business income - HELD THAT:- In any case, even if the AOs action of treating the aforesaid interest income as “Income from other sources”, is finally upheld as it is, then that fact itself cannot prove any concealment of income or furnishing inaccurate particulars of income. The assessee made the claim with proper disclosure in its P&L account supported with other details and documents. In the opinion of the Assessing Officer, the claim on account of interest expenditure was not allowable in full. On the other hand, in the opinion of the Tribunal, the disallowance to the extent of 50% made by AO was not sustainable and thus, only half of the disallowance as was made by the AO was finally sustained by the Tribunal. None of the authortities have branded the claim as bogus. Thus, it is not a case of concealment or furnishing of inaccurate particulars of income and thus, penalty has been wrongly levied on this disallowance and, therefore, the same is directed to be deleted.
Addition u/s 68 - HELD THAT:- This issue has been sent back to the file of the Assessing Officer and, therefore, as on date, penalty does not survive. Thus, penalty on this addition is deleted. The Assessing Officer is free to initiate fresh penalty proceedings after deciding this issue as per law.
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2016 (7) TMI 1531
The 2016 Bombay High Court judgment involved a petition where the petitioners expressed disinterest in pursuing it further. The court dismissed the petition with no costs.
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2016 (7) TMI 1530
Non prosecution of appeal - HELD THAT:- Assessee is not interested in prosecution of the present appeal and the same is liable to be dismissed on this ground itself. Therefore, considering the facts and keeping in mind the provisions of Rule 19(2) of the Income-tax (Appellate Tribunal) Rules, 1963, as were considered in the case of CIT Vs. Multiplan India Ltd. [1991 (5) TMI 120 - ITAT DELHI-D]
Treat this appeal as un-admitted. Accordingly, the appeal is dismissed for want of prosecution. The assessee, if so advised, shall be free to move this Tribunal praying for recalling of this order and explaining the reasons for non-compliance, etc. and if the Bench is so satisfied about the reasons, etc., this order shall be recalled. Appeal of the assessee dismissed for want of prosecution.
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2016 (7) TMI 1529
Undisclosed investment in jewellery - Search operation in the premises of the assessee - credit to the jewellery declared under the VDIS by the assessee’s mother-in-law - wealth tax return was not filed either by the assessee or her husband or by her mother-in-law - AO rejected this claim of the assessee on the ground that the item of jewellery mentioned in the VDIS does not match with the inventory of the jewellery seized during the course of search operation - HELD THAT:- This Tribunal is of the considered opinion that fashion in jewellery is changing day by day and it is the practice of every lady to change the pattern of jewellery in accordance with the latest trend. Therefore, what is to be seen is whether the quantum of jewellery declared matches with the jewellery found during the course of search operation.
When the assessee’s mother-in-law declared 3650 gms of gold jewellery under VDIS, the Assessing Officer is expected to give credit to the jewellery to the extent of 3650 gms. In other words, the jewellery declared by the assessee’s mother-in law is very much available at the residence of the assessee. Therefore, this Tribunal is of the considered opinion that the CIT(A) has rightly directed the Assessing Officer to give credit to the jewellery declared under the VDIS by the assessee’s mother-inlaw Late Smt. Prema. Therefore, this Tribunal do not find any reason to interfere with the order of the CIT(A) and accordingly the same is confirmed. - Decided against revenue
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2016 (7) TMI 1528
Re-assessment order passed u/s. 147 - depreciation at 40% on wheel loaders and wheel graders - CIT-A accepted reopening on the same set of facts after completion of assessment u/s. 143(3) amounts to change of opinion and hence bad in law - CIT(A) directing depreciation at 40% on wheel loaders and wheel graders as against depreciation at 25% allowed by the AO - HELD THAT:- As seen from the assessment order passed u/s. 143(3) originally, AO has considered the claim of depreciation and made certain disallowances out of various depreciation claims made in the schedule. It indicates that AO found the claim of 40% depreciation on the above said vehicles appropriate and allowed the same. Since there is specific discussion on the depreciation claims in the first assessment order, allowance of 40% depreciation by the AO certainly indicates that he has consciously allowed the depreciation at that rate after due examination. Therefore, any opinion by the subsequent AO to restrict the same to 25% is a change of opinion, which is not permitted under the provisions of law.
Moreover the wheel loaders and Graders are Motor vehicles and is certainly eligible for depreciation at 40% as per schedule and the case law on the subject. No reason to interfere with the well reasoned order of the CIT(A), both on the issue of reopening and as well as allowance of depreciation at 40% on wheel loaders. For these reasons, uphold the order of CIT(A) and reject the grounds of Revenue.
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2016 (7) TMI 1527
Disallowance u/s 14A - applicability of provisions of Rule 8D - HELD THAT:- For the Assessment Year under consideration i.e. Assessment Year 2007-08, the provisions of Rule 8D have no application as held by the Jurisdictional High Court in the case of Godrej & Boyce Mfg. Co 2010 (8) TMI 77 - BOMBAY HIGH COURT. It was held that Rule 8D applies only prospectively. Therefore, we hold that provisions of Rule 8D have no application for Assessment Year 2007-08. However, reasonable disallowance should be made and we direct the Assessing Officer to restrict the disallowance under section 14A at 2% of the dividend income as reasonable expenses for earning exempt income. This ground of the assessee is partly allowed
Deduction of disallowance of employees separation cost which was claimed u/s. 37(1) - HELD THAT:- Issue becomes academic in view of the order passed u/s. 143(3) r.w. Sec. 148 wherein the Ld. CIT(A) has given relief. Thus, this ground of the assessee is dismissed.
Disallowance of depreciation claimed on actual cost of the assets as per Sec. 43(1) - Held that:- As for the Assessment Year 2008-09 we find that the Co-ordinate Bench confirmed the order of the Ld. CIT(A) in holding that the Assessing Officer to take the cost of acquisition of assets acquired by it from Tata Motors Ltd., at the cost at which they have been acquired i.e. the actual consideration paid by the assessee.
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2016 (7) TMI 1526
Penalty u/s 271(1)(c) - rejection of books of accounts - HELD THAT:- We find that in the present case the books of accounts were rejected and the income of the assessee was estimated by applying a percentage and therefore, as held by various orders of the Tribunal and High Courts the penalty u/s 271(1) (c) was not imposable in the present case. See SUBHASH TRADING COMPANY [1995 (11) TMI 37 - GUJARAT HIGH COURT] as held in the absence of any other material which might reflect on the conduct of the assessee about a deliberate attempt to maintain false books of account, on a preponderance of probabilities, no other conclusion could be reached than that the failure to return the correct income was no on account of any fraud or gross or willful neglect on the part of the assessee.
As decided in AARKAY SAREE MUSEUM [1990 (8) TMI 97 - BOMBAY HIGH COURT] ribunal had rightly held that merely because certain additions were made in the trading account by the Assessing officer, it did not necessarily follow that assessee had concealed its income the cancellation of penalty was valid. - Decided in favour of assessee.
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2016 (7) TMI 1525
Reopening of assessment u/s 147 - assessee company has diverted interest bearing borrowed funds to group companies without charging any interest - AR argued that the assessee company having same management and due to interse mutual trust with group companies and the concept of business expediency borrowed funds were not utilized for the purpose of advancing interest free loans - HELD THAT: - Assessee company having common directors with other group companies and promoter shareholding. Further, on in depth analyzing M/s. Empee Distilleries Ltd holds 63.43 % of shares alongwith assessee company 2.2% of shares in M/s. Empee Sugars and Chemicals and M/s. Empee Distilleries Ltd holds 27.67% share of the assessee company. The transaction of chain Holding of shares by the assessee company and common individual share holders prove that there exist holding and subsidiary company operations having registered office at one place.
The shares of M/s. Empee Sugars & Chemicals Ltd being 63.43% are directly held by M/s. Empee Distilleries Ltd and we could not understand why the loans was routed through the assessee company. The income of the assessee company is only on redemption of mutual funds and no business activities are carried in the previous year. The explanations that the interest free loan provided to M/s. Empee Distilleries Ltd are out of interest free funds cannot be accepted as the financial statements of the assessee company could not support arguments of AR.
Assessee company on one hand obtain Interest bearing loans from the same management company and give interest free loans to other company in the same management and set off interest charged on loan funds against income on redemption of mutual funds and whereas interest income in the hands of M/s. Empee sugars and Chemicals Ltd does not subject to tax due to Business losses. So, considering the Apparent facts, financial statement, concept of same management and chain holding of shares and tax adjustments, we found that the ld. Commissioner of Income Tax (Appeals) has examined the evidence on record vis-à-vis explanations made by the assessee. We does not see any reason to interfere with the order of Commissioner of Income Tax (Appeals) on this ground
Re-assessment proceedings - as found from the records, against income on redemption of mutual funds, the assessee company has claimed administrative expenditure and finance charges in the nature of interest on advances from M/s. Empee Sugars and Chemical Ltd and also increase in unsecured loans compared to earlier years. The factual matrix that the assessee has not charged any interest on advances to M/s. Empee Distilleries Ltd. But claimed interest in profit and loss account for advances from group company.
AR explained that advances are made on commercial expediency and interest expenditure has to be allowed. All the three companies are under same management and with common shareholding. We are not convinced with the concept of change of opinion as the financial statements clearly shows that the interest was paid on advances but not charged in respect of advances provided to the group company. Further increase in unsecured loans and assessee’s company income is not from business activity but only out of redemption of mutual funds. Therefore, AO was right considering the reasons for re-assessment and issued notice u/s.148 within six years and based on the information as per assessment records and hence the re-assessment proceedings are valid - Decided against assessee.
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2016 (7) TMI 1524
Addition made pursuant to the statement recorded u/s 132(4) - assessee has retracted from the said disclosure which has not been accepted by the revenue - HELD THAT:- Revenue ought to have collected enough evidence during the search in support of the disclosure statement. It is a settled position of law that if an assessee, under a mistake, misconception or on not being properly instructed, is overassessed, the authorities are required to assist him and ensure that only legitimate taxes are collected. The Assessing Officer cannot proceed on presumption u/s 134(2) of the Act and there must be something more than bare suspicion to support the assessment or addition.
In the present case, though the revenue’s case is based on disclosure of the assessee stated to have been made during the search u/s 132(4) of the Act, there is no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income having been found during the search.
As decided in KAILASHBEN MANHARLAL CHOKSHI VERSUS COMMISSIONER OF INCOME-TAX [2008 (9) TMI 525 - GUJARAT HIGH COURT] merely on the basis of admission the assessee could not have been subjected to such additions unless and until, some corroborative evidence is found in support of such admission. From the statement recorded at such odd hours cannot be considered to be a voluntary statement, if it is subsequently retracted and necessary evidence is led contrary to such admission.
As gone through the order passed by the Tribunal no infirmity in the said order. Revenue is not in a position to produce any material on record so as to warrant interference by this Court. The deletion of addition on account of household expenses and cloth transaction has been rightly confirmed by the Tribunal. Tribunal has rightly applied the principles of telescoping for reducing additions made by the Assessing Officer. Decided in favour of the assessee and against revenue.
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2016 (7) TMI 1523
The High Court ordered the case to be put up before a different Bench, excluding one of the current judges, with approval from the Acting Chief Justice. A copy of the order was to be placed in the related case file.
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2016 (7) TMI 1522
Alternative efficacious remedy of appeal - application for possession of the property filed by the respondent Bank - SARFAESI Act - HELD THAT:- The petitioners have an alternative efficacious remedy of appeal against the impugned order. Moreover, the disputed questions of fact have been sought to be raised in the writ petition.
The Apex Court in Commissioner of Income Tax and others vs. Chhabil Dass Agarwal, [2013 (8) TMI 458 - SUPREME COURT], elaborately considered the question of entertaining writ petition where alternative statutory remedy was available.
Appeal dismissed.
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2016 (7) TMI 1521
Suspension of CHA License - regulation 20(2) of the Customs House Agents Licensing Regulations, 2004 - suspension on the ground of failure to obtain authorisation from importer, failure to advise the importer to comply with the provisions of the Customs Act, 1962 and failure to verify the antecedents of importer, the last was not proved but the other two were - HELD THAT:- The proceedings were initiated under the erstwhile Customs House Agents Licensing Regulations, 2004 and completed under Customs Brokers Licensing Regulations, 2013; both these Regulations prescribe a schedule for completion of the proceedings and for each intermediate stage.
The inquiry report is to be submitted within six months of receipt of offence report and decision on revocation passed within another three months thereafter. We find that thirty months have elapsed between the incident and submission of report of inquiry officer. There is no evidence of contributory negligence on the part of the appellant in this delay. The revocation order was itself passed more than seven months after submission of the inquiry report. Besides the delay on the part of the Commissioner, there has been an inordinate and unexplained delay in the entire proceedings from the beginning to the end.
The relationship between the customs broker and licensing authority is a statutory one. While the authority is not employer of the brokers, the brokers themselves are dependent upon the licence for their livelihood, as well as that of their dependents and their employees. Considering the relationship, though certainly not one of master-servant, revocation of a licence has as grave consequences as that of dismissal of an employee in an organisation. Accordingly, the sanctity of procedure and adherence to principles of natural justice can be no less, rigorous than that prescribed for disciplinary proceedings.
The Regulations prescribe strict adherence to time-lines and, in the event of non-compliance, the proceedings stand vitiated - the restoration of licence of the appellant is directed with immediate effect.
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2016 (7) TMI 1520
Penalty u/s 158BFA(2) - order barred by limitation - HELD THAT:- the date of the order of the Tribunal is 12.10.2006 and the date of the High Court order is 29.11.2010 and penalty order is passed on 19.05.2011 therefore provisions of section 158BFA(3)(c) extends the period of limitation in the matter of appeal before the Tribunal only and not on appeal before the Hon’ble High Court. Therefore the penalty order is passed beyond the period of limitation as provided u/s 158BFA(3)(c) of the Income Tax Act.
as the date of the Tribunal order is 12.10.2006, the penalty should have been levied within 6 months from the end of the month in which the order of the Tribunal is received which in any case is violated as the penalty order is passed on 19.05.2011.
As the date of the Tribunal order is 12.10.2006, the penalty should have been levied within 6 months from the end of the month in which the order of the Tribunal is received which in any case is violated as the penalty order is passed on 19.05.2011.
In this case the order of the tribunal is dated 12.10.2006 and penalty order is passed on 19.05.2011, therefore, apparently the order is barred by limitation. The decision relied upon by the ld AR of coordinate bench of Arvind Kr. Jain Vs. ACIT [2012 (9) TMI 1159 - ITAT AGRA] has decided the issue on identical facts and circumstances, wherein such order of penalty was barred by limitation - Decided in favour of assessee.
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2016 (7) TMI 1519
Exemption u/s 10(10)(i) and 10(10AA)(i) - Denial of exemption in respect of the amount received by the assessee towards arrears of gratuity and arrears of leave encashment - view taken by the AO that the assessee was not a `holder of civil post under the State Government’ and hence not eligible for exemption u/s 10(10)(i) - assessee was held to be not covered u/s 10(10)(ii) as he did not receive any gratuity under the Payment of Gratuity Act, 1972 - HELD THAT:- Delhi bench of the tribunal in Shri Ram Kanwar Rana vs. ITO, Ward-3, Hisar [2016 (6) TMI 687 - ITAT DELHI] has allowed exemption in respect of the arrears of gratuity and arrears of leave encashment and dismissed the grounds about the initiation of reassessment. Similar view has been taken in the case of Raghubir Singh Panghal vs. ITO [2016 (6) TMI 1163 - ITAT DELHI].
Following the same, extend the benefit of exemption to the instant assessee also in respect of arrears of gratuity and arrears of leave encashment u/s 10(10)(i) and 10(10AA)(i).
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2016 (7) TMI 1518
Denying the deduction u/s 80P(2) - claim of deduction u/s 80P (2) was denied by the AO for the reason that the assessee is primarily engaged in the business of banking and in view of section 80P(4) of the Act, the assessee is not entitled to deduction u/s 80P(2) - HELD THAT:- The Hon’ble jurisdictional High Court in the case of The Chirakkal Service Cooperative Bank Ltd & others [2016 (4) TMI 826 - KERALA HIGH COURT] has held that the primary agricultural credit society registered under the Kerala Cooperative Societies Act, 1969 is entitled to the benefit of deduction u/s 80P(2).
The primary agricultural credit societies, registered as such under the KCS Act; and classified so, under that Act, including the appellants are entitled to such exemption - Decided in favour of assessee
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2016 (7) TMI 1517
Levy of penalty u/s 271(1)(b) - assessee not complied with the notice u/s 142(1) - HELD THAT:- Where the assessee had not complied with the notice u/s 142(1) but the assessment order was passed u/s 143(3) and not u/s 144 of the Act, that meant the subsequent compliance in the assessment proceedings was considered as good compliance and the defaults committed earlier were ignored by the AO and therefore, the levy of penalty u/s 271(1)(b) was not justified.
Considering the same as well as respectfully following the decision of AKHIL BHARTIYA PRATHMIK SHIKSHAK SANGH BHAWAN TRUST. VERSUS ASSISTANT DIRECTOR OF INCOME-TAX. [2007 (8) TMI 386 - ITAT DELHI-G] and also following the principle of consistency, we are of the opinion that these are not the fit cases for invoking the provisions of section 271(1)(b) of the Act. Accordingly, grounds raised by the assessee in all the seven appeals are allowed.
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2016 (7) TMI 1515
Demand u/s 201 - barred by limitation - proceedings initiated within the permissible time limit or not ? - HELD THAT:- In the case of the assessee, we noted that the Assessing Officer initiated the proceedings u/s 201(1)/201(1A) for the impugned assessment year on 09/02/2007. The proceeding was not concluded. The proceedings remained pending as on the date when the proviso to section 201(3) was inserted by the Finance Act No. 2 of 2009 with effect from 01/04/2010. It is not denied by the Learned A. R. of the assessee that the proceedings were pending as on 01/04/2010. The proviso to section 201(3) therefore, was clearly applicable in the case of the assessee which mandates that such order for a financial year commencing on or the first day of April, 2007 may be passed at any time on or before 31st day of March 2011. We noted that in the case of the assessee, the Assessing Officer has passed the impugned order on 10/03/2011 therefore, on this basis itself it cannot be said that the order passed by the Assessing Officer was barred by limitation.
We may mention that in the case of NHK Japan Broadcasting Corporation [2008 (4) TMI 182 - DELHI HIGH COURT] as well as in the case of CIT v. Hutchison Essar Telecom Ltd. [2010 (4) TMI 45 - DELHI HIGH COURT] have held that the proceedings u/s 201(1) and 201(1A) of the Act can be initiated only within three years from the end of the assessment year or within four years from the end of the relevant financial year. In the case of the assessee, the relevant assessment year is the assessment year 2005-06 while the financial year is 2004-05. The Assessing Officer has initiated the proceedings on 09/02/2007. On the basis of these decisions also, the proceedings were initiated by the Assessing Officer within the permissible time. - Decided in favour of revenue.
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2016 (7) TMI 1514
Misappropriation of funds - attachment of properties - offences Under Sections 409, 468 read with Section 471 of the Indian Penal Code - HELD THAT:- There has been a gross mis-carriage of justice at several steps. In the first place, the finding of the trial court that Ramachandraiah was alone responsible for the offences is completely vitiated as null and void since Ramachandraiah had admittedly died on the date this finding was rendered. It is too well settled that a prosecution cannot continue against a dead person. A fortiori a criminal court cannot continue proceedings against a dead person and find him guilty. Such proceedings and the findings are contrary to the very foundation of criminal jurisprudence. In such a case the accused does not exist and cannot be convicted.
The learned District Judge committed a gross error of law in acting upon such a finding and treating Ramachandraiah as guilty of such offences while making the order of attachment and while confirming the said order of attachment of properties.
There is no legal provision which enables continuance of prosecution upon death of the accused. We must record that the proceedings and the decisions of the courts below are disturbing, to say the least. In the first place, though the accused had died, the trial court proceeded with the trial and recorded a conviction two years after his death. Then, this null and void conviction was used as a basis for making an attachment of his properties before the Sessions Court. Astonishingly, all applications succeeded, the attachment was made absolute and over and above all, the High Court upheld the attachment.
Appeal allowed - decided in favor of appellant.
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2016 (7) TMI 1513
The Supreme Court of India condoned delay and granted leave in a case tagged with Civil Appeal No.14528/2015. The reference was from the Madras High Court. Judges were Mr. Kurian Joseph and Mr. Rohinton Fali Nariman. Petitioner represented by Mr. Ranjit Kumar, SG, Mr. Rupesh Kumar, Mr. Manish Pushkarna, and Mrs. Anil Katiyar.
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2016 (7) TMI 1512
Disallowance of deduction of actual payment made to Life Insurance Corporation of India under Group Gratuity Insurance Scheme - such scheme was not specifically approved by concerned Commissioner of Income Tax though carried under general approval of Central Government - liable to be treated as payment made to a fund which is deemed to have been approved by the CIT by the reason of efflux of time - As argued that premium claimed as deduction was an actual payment and not provisional, therefore, Section 40A(7) was not applicable - HELD THAT:- It is admitted by Revenue that the amount claimed to be paid by Assessee under Group Gratuity Insurance Scheme is the actual payment made to LIC and not something which can be said to be a provision made by Assessee for payment of gratuity. Deduction towards gratuity fund is permitted under Section 36(1)(v) which reads as under : - “any sum paid by the assessee as an employer by way of contribution towards an approved gratuity fund created by him for the exclusive benefit of his employees under an irrevocable trust; ”
Other authorities have committed manifest error in treating the fund as non approved on the basis of order dated 25.6.2012 passed by Commissioner and disregarding specific requirement of law under Section 12AA(2) of Act, 1961.
Gratuity fund of Assessee stood deemed to have been registered and that being so subsequent order passed by CIT(Appeals) had no consequence or illegal effect. Hence, Assessee was entitled to claim deduction under Section 36(v). The view taken otherwise in impugned orders, therefore, is illegal, and contrary to law and observing to be set aside.
5% income in term of premium received during concerned assessment years and deduction under Section 80IA and applicability of provision - HELD THAT:- There is no justification for presuming income of 5% as total premium received by Assessee, for the reason that premium received is nothing but allotment of land to entrepreneur and facility of returning expenses incurred by Assessee for development of such industrial land and there is no concept of profit or loss in such determination. Amount paid by allottees represents lease rent etc. and hence assumption of 5% income on such premium is without any basis.
Similarly for interest received by Assessee on delayed payment of installment of premium or lease rent etc Tribunal has completely erred in law inasmuch as a finding of fact was recorded by CIT that interest earned by Assessee on installments granted in respect of premium payable, and other income etc. receipts may have some link with the business of appellant and having said so, still it has reversed order of Assessing Authority to the extent, it has allowed deduction under Section 80IA on such 'interest' and Tribunal has erred in law in failing to appreciate this finding of Commissioner of Income Tax ( Appeals) and without reversing the same, has dismissed Assessee's appeal.
Thus Assessee was entitled for deduction towards payment of group gratuity insurance paid to LIC by treating fund as any approved fund. 5% of premium collected by Assessee and forfeiture of earnest money/premium has been added illegally based on conjuncture and surmises. Since the nature of functioning of Assessee has not been examined looking to the public nature of its functioning for development of industries in the State, such addition, therefore, is not justified in law.
Applicability of Section 80IA, without reversing findings of CIT(Appeals), that such interest received may have some link with the business of appellant and once that is so, to hold that deduction under Section 80IA is not admissible is per se contradictory and hence is not correct and in accordance with Law.
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