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Showing 221 to 240 of 1621 Records
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2016 (5) TMI 1406
Detention of property - property in the nature of a factory with plant and machinery - order of attachment - recovery of outstanding dues of the Customs Department - liability of last owner - the decision in the case of C OIL EXIM LTD. Versus UNION OF INDIA [2015 (9) TMI 1594 - GUJARAT HIGH COURT] contested, where it was held that The subsequent owner had agreed to discharge the dues of the erstwhile owner, the question whether it was the property of the business which was sold need not be gone into - Held that: - the decision in the above case upheld - SLP dismissed.
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2016 (5) TMI 1405
Deduction under Section 80IB - denial of claim on the ground that the activity of filling the gas into the cylinders does not constitute manufacturing and the LPG bottling Plants are part of the refining activities and cannot be considered as independent industrial undertakings - Held that:- The assessee's are entitled for deduction under section 80IA in respect of filing of LPG bottling Plants. See COMMISSIONER OF INCOME TAX-1 Versus M/s HINDUSTAN PETROLEUM CORPORATION LTD. [2013 (5) TMI 124 - BOMBAY HIGH COURT]
Allowable deduction under section 80IA - claim for C3 and C4 plants in respect of Special Cut Naptha (SCN) plant - Held that:- We find that the year of commission of C3 & C4 SCN plant is 1991-92. This is the 10th year claim of deduction. In the earlier year, the revenue has allowed the deduction based on profit formula by taking the cost of the project into the business profit into percentage specified u/s 80IA of the Act upon Opening gross block of the corporation.
The assessee has also given working of the computation of deduction on the basis of the same formula. Once on a particular formula, a deduction has been allowed then same should have been uniformly followed for the last year also. Accordingly, we direct the AO to examine the working of the assessee corporation and work out the allowable deduction under section 80IA to the assessee
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2016 (5) TMI 1404
Issues Involved:
1. Addition to the international transaction based on Chapter X of the Income-tax Act.
2. Rejection of comparable companies by TPO/AO.
3. Identification of new comparable companies by TPO/AO.
4. Erroneous computation of margins for arm's length price adjustment.
5. Non-consideration of specific provisions of Rule 10B(i)(e)(iii) for adjustments.
6. Disregarding contemporaneous multiple year data.
7. Non-satisfaction of conditions under Section 92C(3) before making an adjustment.
8. Non-allowance of 5% variation benefit under Section 92C(2).
9. Initiation of penalty proceedings and levying interest under Sections 234A, 234B, and 234C.
Detailed Analysis:
1. Addition to the International Transaction Based on Chapter X:
The assessee contested a Rs. 3,12,91,568 addition made to its international transaction by the TPO/AO under the directions of the DRP. The Tribunal noted that the assessee was engaged in ITES services to its associate enterprises and had applied the TNMM method for determining the arm's length price. The TPO had selected 10 comparable companies, but the DRP later reduced it to 8. The Tribunal found merit in the assessee's claim and directed the exclusion of certain companies from the final set of comparables, resulting in a reduction of the TP adjustment.
2. Rejection of Comparable Companies by TPO/AO:
The TPO/AO rejected certain comparable companies proposed by the assessee. The Tribunal agreed with the assessee's contention that Cosmic Global Ltd., Informed Technologies India Ltd., and Accentia Technologies Ltd. were not functionally comparable due to different business models, extraordinary events, and low employee cost ratios, respectively. The Tribunal directed their exclusion from the final set of comparables.
3. Identification of New Comparable Companies by TPO/AO:
The TPO/AO included new companies in the final set of comparables without appreciating that they were not comparable to the assessee. The Tribunal found that the inclusion of Accentia Technologies Ltd. was incorrect due to extraordinary events like acquisition and amalgamation. Similarly, Cosmic Global Ltd. and Informed Technologies India Ltd. were excluded due to their different business models and low employee cost ratios.
4. Erroneous Computation of Margins for Arm's Length Price Adjustment:
The assessee argued that the TPO/AO computed erroneous margins for arriving at the arm's length price. The Tribunal directed the correction of margins for Jeevan Softech Ltd., noting that the TPO had failed to consider segmental revenue correctly. The corrected margin was to be 8.04% instead of 39.38%.
5. Non-Consideration of Specific Provisions of Rule 10B(i)(e)(iii) for Adjustments:
The assessee claimed that the TPO/AO did not consider the specific provisions of Rule 10B(i)(e)(iii) for adjustments. The Tribunal did not address this issue separately as the exclusion of certain comparables and correction of margins resolved the main contention.
6. Disregarding Contemporaneous Multiple Year Data:
The assessee contended that the TPO/AO disregarded contemporaneous multiple year data. The Tribunal upheld the use of single year's data as per Rule 10B(4), unless evidence showed that the single year's data was not functionally similar.
7. Non-Satisfaction of Conditions Under Section 92C(3) Before Making an Adjustment:
The assessee argued that the TPO/AO did not satisfy the conditions under Section 92C(3) before making an adjustment. The Tribunal did not address this issue separately as the exclusion of certain comparables and correction of margins resolved the main contention.
8. Non-Allowance of 5% Variation Benefit Under Section 92C(2):
The assessee claimed the benefit of 5% variation under Section 92C(2). The Tribunal noted that with the corrected set of comparables, the assessee's margins were within +/- 5% of the average margins, making this ground infructuous.
9. Initiation of Penalty Proceedings and Levying Interest Under Sections 234A, 234B, and 234C:
The assessee contested the initiation of penalty proceedings and levying of interest. The Tribunal found the initiation of penalty proceedings premature and dismissed this ground as premature.
Revenue's Appeal:
The Revenue contested the exclusion of Eclerx Services Ltd. as a comparable. The Tribunal upheld the exclusion, citing the Hon'ble Delhi High Court's decision in Rampgreen Solutions Pvt. Ltd. Vs. CIT, which held that Eclerx Services Ltd., being a KPO, was not functionally comparable to a BPO.
Conclusion:
The Tribunal partly allowed the assessee's appeal by directing the exclusion of certain comparables and correction of margins, resulting in no addition to the assessee's income on account of arm's length price adjustment. The Revenue's appeal was dismissed.
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2016 (5) TMI 1403
Addition u/s 40A(2)(b) - incentive paid to ICICI Bank - disallowance of 50% of brokerage earned by the assessee - Held that:- For making disallowance u/s.40A(2)(b) onus is on revenue to prove unreasonableness.
As found that since the bonds were acquired by ICICI Bank (l-Bank) and aforesaid entities, which were financial institutions and not retail investors, there was no expenditure incurred by the assessee towards marketing in retail business. The pass on of such incentive was based on the market practice followed in assessee’s line of business. Incentive passed on to I-bank was duly offered to tax by that client in its return of income. As regards the reasonableness, the incentive passed on to I-Bank was comparable to other two independent entities. Therefore, the incentive paid to I-Bank was allowable u/s.37(1) of the Act. Thus, we do not find any merit in the action of CIT(A) for upholding the disallowance of 50%. The AO is directed to delete the entire disallowance so made.
Disallowance of 25% on procurement expenses made to I-Bank - addition as it is unreasonable and not incurred wholly and exclusively for the purpose of assessee’s business - Held that:- As carefully gone through the order of Tribunal and found that exactly similar issue was dealt by the Tribunal in assessee’s own case and entire disallowance so made by the AO was deleted. As the facts and circumstances during the year under consideration are same, respectfully following the order of the Tribunal in assessee’s own case, we direct the AO to delete the disallowance so made on account of procurement expenses.
Disallowance of software expenses - revenue or capital expenditure - Held that:- The issue under consideration is squarely covered by the decision of Hon’ble Bombay High Court in the case of Raychem RPG Ltd.(2011 (7) TMI 953 - Bombay High Court). Respectfully following it, we do not find any merit for disallowance of software expenses of ₹ 1,20,000/- so incurred by assessee, which is essentially revenue in nature.
Invoking Explanation to Section 73 and treating share trading loss as speculative loss - Held that:- The issue has been decided by Hon’ble Bombay High Court in the case of Prasad Agents [2009 (3) TMI 35 - BOMBAY HIGH COURT] against the assessee.
Disallowance on account of depreciation on BSE membership card - Held that:- No infirmity in the order of CIT(A) for allowing assessee’s claim for depreciation on BSE Membership Card. See Techno Shares & Stocks Ltd., [2010 (9) TMI 6 - SUPREME COURT OF INDIA].
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Transaction between the assessee company and ICICI Securities INC was at arm’s length and in accordance with provisions of TP rules - AO has disallowed client’s introduction fee paid to the ICICI (INC) (ISI) on the plea that expenditure was not incurred for the purpose of assessee’s business - Held that:- . Ground raised by revenue in the assessment year 2004-05 are similar to the ground discussed by us for the assessment year 2003-04 wherein held as found from the record that ISI is an entity based in USA and assessee has rendered services abroad to clients developed by ISI. By invoking provisions of Section 40A(2)(b), the AO has made disallowance. However, the AO has not given any specific details in support of this disallowance. After giving detailed finding at para 5.2, the CIT(A) concluded that payment made to ISI was as per prevailing market conditions and it was within norms fixed by BSE. Accordingly, the AO was not justified in making disallowance out of introduction fee paid to ISI. The detailed findings so recorded by CIT(A) are as per material on record. Ld. DR has not brought any positive material on record to controvert the finding of CIT(A). Accordingly, we do not find any reason to interfere in the findings of CIT(A) resulting into deletion of disallowance out of introduction fee paid to ISI.
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2016 (5) TMI 1402
The High Court of Andhra Pradesh dismissed the Writ Petition as withdrawn upon the petitioner's request. No costs were awarded.
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2016 (5) TMI 1401
Penalty levied u/s. 271(1)(c) - addition on account of certain bogus purchases - Held that:- The materials brought on record are sufficient to establish that the purchases reportedly made by the assessee from the parties recorded in the books, were not purchased from them. It is equally true that the assessee would not have been above to sell the goods without making purchases. It is quite possible that the assessee might have purchased the goods from gray market without proper receipts and in that process saved about 25% or so as the price of the goods in the gray market is lower than the price of the goods charged by the reputed dealers. In this view of the matter, it would be proper to restrict the disallowance to the extent of 25% of the bogus purchases reportedly made by the assessee. The Assessing Officer is directed to restrict the addition to 25% of the bogus purchases in all the three years.
Thus it shows that the restriction of the disallowance is made purely on estimation. Thus, it can be safely concluded that the additions were made on mere presumption and not on the basis of any material fact not disclosed by the assessee. A perusal of the orders of the authorities below in the assessment proceedings show that the purchases were well supported by bills/invoices though the parties from whom the purchases were made were found to be either name lenders or issuing accommodation bills.Thus levy of penalty u/s. 271(1)(c) of the Act not to be levied - Decided in favour of assessee.
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2016 (5) TMI 1400
Dispensation of meetings of Equity Shareholders, Secured Creditors and Unsecured Creditors of the Applicant Company - dispensation of the procedure as envisaged under Sections100 to 103 of the Companies Act, 1956 - Held that: - all the Equity Shareholders, Secured Creditors as well as the Unsecured Creditors of the Applicant Company have approved the Scheme in the form of the written consent letters - dispensation of meetings granted.
Since the reduction results due to cancellation of shares by operation of law, it does not involve either diminution of liability in respect of unpaid share capital or payment to any shareholder of any paidup share capital and the order of the Court sanctioning the Scheme shall be deemed to be an order under Section 102 of the Companies Act confirming the reduction - the procedure prescribed under Section 101(2) of the Companies Act, 1956 and under rule 48 to 65 of the Companies (Court) Rules 1959 is not necessary to be followed and the same is hereby dispensed with.
Application allowed.
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2016 (5) TMI 1399
Reopening of assessment - Held that: - having noted that the reasons recorded for reopening of the assessment do not suggest anything more than the verification, we are of the considered view that the very initiation of reassessment proceedings on the facts of this case is unsustainable in law - we deem it fit and proper to quash the reassessment proceedings - appeal allowed.
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2016 (5) TMI 1398
Scheme of Amalgamation - dispensation of the meetings of the Equity Shareholders and Unsecured Creditors on the ground that the consent of all the Equity Shareholders and Unsecured Creditors of the Company has been obtained in writing and produced on record - Held that:- Notice to the Central Government, through the Regional Director, ROC Bhavan, Opp. Rupal Park Society, Behind Ankur Bus Stop, Naranpura, Ahmedabad380013. Notice is also directed to be issued upon the Official Liquidator with a direction to appoint a Chartered Accountant for the preparation and submission of the report at the cost of the petitioner.
Notice of the hearing of the petition to be published in the English daily newspaper “Indian Express” and the Gujarati daily newspaper “Gujarat Mitra”, having circulation in Surat. The publication of the notice in the Government Gazette is dispensed with.
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2016 (5) TMI 1397
Scheme of Arrangement - Held that:- The certificates confirming the status of the Shareholders and Creditors as well as the receipt of the consent letters from all the Shareholders are annexed collectively as Exhibit ‘F’. In view of the same, dispensation is sought from convening the meetings of the Equity Shareholders and Preference Shareholders of the Applicant Company. Considering the above facts and circumstances and the submissions advanced, the same is hereby granted.
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2016 (5) TMI 1396
Sanction of the Composite Scheme of Arrangement - Held that:- The Court had dispensed with the requirement of convening the meetings of the Equity Shareholders and Preference Shareholders. Similarly, the requirement of convening and holding of the meeting of the Secured Creditors was ordered to be dispensed with. This court directed the Petitioner Company to send individual notices to the Secured Creditors of the Petitioner Company. Similarly, the requirement of convening and holding of meeting of the Unsecured Creditors was ordered to be dispensed with.
The petition is admitted. The same shall be posted for final hearing on 22nd June, 2016. Notice of the petition to be published in the Ahmedabad editions of the Gujarati daily newspaper “Jai Hind” and the English daily newspaper “DNA”.
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2016 (5) TMI 1395
Scheme of arrangement - dispensing with the meeting of the Equity Shareholders, Preference Shareholders, Secured and Unsecured Creditors of the Applicant Transferee Company - Held that:- (a) The meeting of the Equity Shareholders of the Applicant Transferee Company is dispensed with in view of the consent letters of 99.95% of the Equity Shareholders and the Chartered Accountant’s certificate certifying the list of Equity Shareholders.
(b) The meeting of the Preference Shareholders of the Applicant Transferee Company is dispensed with in view of the consent letters of 87.96% of the Preference Shareholders and the Chartered Accountant’s certificate certifying the list of Preference Shareholders.
(c) The meeting of the Secured Creditors is dispensed with in view of the fact that there 4 (Four) Secured Creditors and no compromise is sought to be offered to the Secured Creditors and the Secured Creditors of the Applicant Company will be paid in the ordinary course of business. However, the Applicant Transferee Company shall send individual notices to the Secured Creditors and on receipt of the views/opinion of the Secured Creditors, this Court shall be informed of the same.
(d) The meeting of the Unsecured Creditors of the Applicant Transferee Company is dispensed with, in view of the fact that the rights and interest of the Unsecured Creditors is not affected by the proposed Scheme of Arrangement and as no compromise or arrangement is offered to the Unsecured Creditors.
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2016 (5) TMI 1394
Validity of notice u/s 143(2) - not validly served upon the assessee - notice u/s 143(2) of the Act was issued by non jurisdictional AO of Ward 32(4) instead of jurisdictional AO of the ITO, Ward 6(1), New Delhi - applicability of provisions of section 292BB - Held that:- The notice issued by non jurisdictional ITO of Ward 32(4) dated 19.10.2007 was handed over to the postal authorities containing in an envelope and the address mentioned in the notice was as per return of income but the address noted by the postal authorities is incomplete and presumption of valid service of notice on the basis of copy of the postal record, as relied by the Revenue cannot be made and thus we are inclined to accept contention of the assessee towards attempt of rebuttal of presumption that the first notice dated 19.10.2007 was issued by the non jurisdictional AO and the notice was handed over to the postal authorities containing incomplete and incorrect address on the envelope as address mentioned by the AO in the copy of the notice is “Micro Spacematric Solution Private Limited, 32/205, First Floor, Vikram Vihar, Lajpat Nagar IV, New Delhi 110 024” whereas thë address noted by the postal clerk from the envelope was “Micro Spacematrix Solution, Sohel, 32/205, Vikram Vihar, which clearly shows that the address noted by the postal authorities from the envelope containing said notice was dated 19.10.2007 not only incomplete but it was incorrect. Hence, valid presumption of service of notice in favour of Revenue and against the assessee cannot be made.
So far as the applicability of provisions of section 292BB of the Act is concerned, firstly it is not applicable to A.Y 2006-07 under consideration and secondly, the assessee raised objection regarding non service of notice dated 19.10.2007 on 5.11.2008 [paper book page 3] replying to the notice dated 7.10.2008 wherein he categorically objected to the service of second notice dated 7.10.2008 notice beyond prescribed time limit. So far as objection to first notice dated 19.10.2007 is concerned when this notice was not properly served upon the assessee then how the assessee can be expected to file objection against the notice which has not been served upon him. The assessee filed its objection on 5.11.2008 [paper book page 2] when he received notice dated 7.10.2008 alleging time barring which complete the requirement of proviso to section 292BB of the Act. Hence, on the basis of foregoing discussion and legal contention of the ld. DR are jettisoned and rejected. - Decided in favour of assessee.
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2016 (5) TMI 1393
CENVAT credit - inputs/capital goods - M.S. Angles, H.R. Coils, Sections, Joints, Channels, Cements etc. - penalty - Held that: - the issue regarding entitlement of cenvat credit on disputed goods were highly debatable and the Larger Bench of this Tribunal in the case of Vandana Global Ltd. Vs. CCE [2010 (4) TMI 133 - CESTAT, NEW DELHI (LB)] has held that Central Excise duty paid on such goods are not available for cenvat credit.
Penalty - Held that: - the period involved in this case is from 15.04.2008 to 19.01.2009, which is prior to the date of amendment of Rule 2(k) ibid and also pronouncement of the decision by this Tribunal in the case of Vandana Global - malafides cannot be attributed for imposition of penalty on the appellant.
Appeal allowed - decided partly in favor of appellant.
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2016 (5) TMI 1392
Reopening of assessment - allowance of claim under Section 35AB - Held that:- Provisions of Section 147 of the Income Tax Act, 1961 can be invoked when an assessee is guilty of not disclosing fully and truly all materials facts necessary for its assessment for that assessment year. In the facts of the case the allegation is that the petitioner had claimed deductions in excess of the amount that it is entitled to for the relevant year. The impugned order dated May 22, 2001 alleges that the petitioner is guilty of failing to disclosure fully and truly all relevant facts for the allowance of claim under Section 35AB of the Income Tax Act,1956 and, therefore, income assessable to tax had escaped assessment.
The petitioner had entered into an agreement with a foreign supplier for the purpose of acquiring technical knowhow. This agreement was disclosed to the Assessing Officer. The petitioner had sought permission from the Assessing Officer to remit the technical knowhow fees to the foreign supplier. This fact would appear from the exchange of correspondence between the petitioner and the assessment officer dated June 22, 1993, December 13, 1996 and December 19, 1996. In fact, the Assessing Officer had granted permission by writing dated December 19, 1996 to make the remittance. The petitioner has also disclosed its audited balance-sheet as also the quantum of remittance made and the manner calculated and arriving at the quantum of deductions claimed by the petitioner for the relevant assessment year. The assessment year was assessed on scrutiny under Section 143(3) of the Income Tax Act, 1961. The Assessing Officer was silent on account of the deductions claimed. He had allowed the amount of deductions claimed on such head in the order of assessment under Section 143[3] of the Income Tax Act, 1956.
The petitioner is not guilty of disclosing fully and truly all materials facts necessary for its assessment for the relevant assessment year. Therefore applying the ratio laid down in Gemini Leather Stores (1975 (5) TMI 1 - SUPREME Court) and Ganesh Housing Corporation Ltd (2012 (3) TMI 211 - GUJARAT HIGH COURT) even if the assessment had escaped the notice of Assessing Officer, the provisions of Section 147 of the Income Tax Act, 1961 cannot be invoked to address such issue.
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2016 (5) TMI 1391
Disallowance of cash expenses - addition u/s 40A - Held that:- As looking to the nature of expenses incurred by the assessee, it is difficult to get a third party bill for most of the expenses and incurring of cash expenses in this line of activities seems to be quite inevitable. However, looking to the facts and circumstances and that some of the expenses cannot be put to full verification, therefore, in the interest of justice, we are reducing the disallowance of cash expenses to 5%. Accordingly, the disallowance on account of cash expenses would be 5% and thus the ground raised by the assessee is partly allowed.
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2016 (5) TMI 1390
Scheme of Amalgamation - dispense with the requirement of convening the meetings of their equity shareholders, secured and unsecured creditors - Held that:- In view of the submissions made at the bar, the settled law on the subject, and considering the Scheme of Amalgamation, the requirement of convening and holding the meetings of the equity shareholders, secured and unsecured creditors of the transferee company, to consider and if thought fit, approve, with or without modification, the proposed Scheme of Amalgamation, is dispensed with. Further, the requirement of the transferee company to file the second motion petition for sanction of the Scheme of Amalgamation is also dispensed with.
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2016 (5) TMI 1389
Depreciation claim to assessee trust - Held that:- Allowability of depreciation on capital assets acquired for the purposes of carrying out charitable activities and set off of deficit of earlier years against income of the current year. The impugned order in fact followed decision of this Court in CIT v/s. Institute of Banking Personnel Services [2003 (7) TMI 52 - BOMBAY High Court] while holding in favour of the Respondent-Assessee.
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2016 (5) TMI 1388
Addition u/s 68 - unexplained cash credit - proof of genuine deposits - discharge of burden of proof - Held that:- On a careful consideration of the documents filed by the assessee and the explanations given by it, and without reference to evidences in the form of statement recorded from Shri S.K. Jain or the material seized by the investigation wing to the extent used against the assessee, we hold that the assessee has not discharged the burden of proof that lay out on it, to prove the genuineness of these cash credits as well as the creditworthiness of the share applicant companies. In view of the above discussions, the addition made by the AO u/s 68 of the Act is upheld and the order of the Ld. CIT(A) is vacated. - Decided against assessee.
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2016 (5) TMI 1387
TPA - comparability - selection procedures - determining the arm’s length price of international transactions between associated enterprises if the comparable selected are operating since long and the assessee is in the initial stages of operation - Held that:- The losses incurred by the assessee cannot be the basis for finding out the arm’s length price without making due adjustments to the operating expenses so as to bring it at the level playing field with the comparables. In the course of hearing the ld. Counsel pointed out that break even was arrived at in next year and ld. TPO has accepted the transactions being at arm’s length price in next year. One of the contentions of the ld. CIT DR was that this plea was not taken before ld. TPO but, as reproduced earlier, before ld. DRP, specific objection to this effect had been taken. Therefore, merely on the ground that this plea was not taken, assessee’s claim cannot be denied more particularly because not allowing for this adjustment would go against the very principle of comparability criteria contemplated under Rule 10B of the I.T. Rules. We further find that though ld. DRP had given direction for inclusion of commission income as part of the operating income but except PAE Ltd. all other comparables were not having any commission income.
As rightly suggested by the assessee, the proper course would be to restore the matter to the file of ld. TPO to find out fresh comparables having trading and commission income both and include the same after making adjustments as mandated by the law. Ld. TPO will also examine the details as per annexure 3 and any further details as may be necessary to consider and will make adjustments to salary and rental income and other adjustments so as to bring the profitability of assessee inconformity with the profitability of the comparable after providing due opportunity of hearing to the assessee.
Addition of ROC expenses incurred in connection with increase in authorized share capital - Held that:- Hon’ble SC in the case of Brook Bond India Ltd. (1997 (2) TMI 11 - SUPREME Court) had considered the expenditure in connection with additional issue of shares and had held that expenditure directly related to expansion of capital base and was therefore, capital in nature. This decision is subsequent to the decision relied upon by the assessee in the case of Multi Metals Ltd. [1990 (10) TMI 55 - RAJASTHAN High Court ] and, therefore, we are not inclined to accept the additional plea raised by ld. Counsel for the assessee.
Allowability of recruitment expenses, training expenses and entertainment expenses - this was the first year of assessee’s business and the assessee had incurred all these expenses to start its business - Held that:- The relevant date for deciding whether an expenditure is pre operative or post operative is the date of setting up of business and not the date of commencement of business. Both the lower revenue authorities have not examined this aspect and, therefore, we restore this issue to the file of AO to examine the issue afresh with the light of aforementioned decisions.
Claim of provision for gratuity - assessee had made this provision as 6% of the sales - Held that:- AO correctly disallowed the assessee’s claim, inter alia, observing that estimation was not based on any statistical analysis or any historical data base. He further pointed out that this was the first year operation of the assessee and, therefore, assessee was not having any prior experience.
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