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Showing 241 to 260 of 1510 Records
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2015 (1) TMI 1277
Revokation of CHA licence - Import of mobile accessories from China - Misdeclaration with respect to value and quantity in respect of some items - Appellant urges that initial suspension was bad being made more than a year after the cause of action arose with the Revenue and processes of inquiry is still not completed and no substantial progress have been made in the matter of inquiry. Appellant have already suffered suspension for more than 14 months.
Held that:- it is found that under similar circumstances when the inquiry proceedings have been delayed and/or the suspension was made after a substantial delay of several months from event relating to the suspension, this Tribunal have revoked the suspension, granting liberty to the authorities to expedite the inquiry and complete the proceedings in the matter, in accordance with law. Accordingly, in the interest of justice, the impugned suspension is invoked and is ordered with a direction to the Custom Authorities to conduct and complete the inquiry as provided for in the CHALR/CBLR and on completion of inquiry, take action against the appellant in accordance with law. - Decided in favour of appellant
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2015 (1) TMI 1276
Addition u/s 41(1) r.w.s. 43B - taxability of sales tax amount collected and not paid during the current assessment year - deferred tax liability - Held that:- This court had an occasion to consider the said question of law in the assessee's case itself in CIT v. McDowell and Co. Ltd. [2014 (11) TMI 272 - KARNATAKA HIGH COURT ] in favour of assessee
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2015 (1) TMI 1275
Disallowance of foreign currency derivative loss by treating it as speculation loss - not allowing set off against regular business - Held that:- The definition of “speculative transaction”, will not apply to a situation where the purpose of entering a forward contract was to hedge/safeguard against any loss on account of repayment of principal amount of the loan: cancellation of the contract was identical to that object and consequently any loss/gain arising from such cancellation is directly related to repayment of the loan. Further, attention is also drawn to proviso (c) to s.43(5) of the Act, which excludes a contract entered into by a member of a forward market or a stock exchange in the course of any transaction in the nature of jobbing, etc. to guard against loss which may arise in the ordinary course of his business to such member from the definition of speculative transaction. Thus we hold that Forex contracts entered into by the assessee will not fall under the definition of “speculative transaction” - Decided in favour of assessee.
Denial of duty draw back while computing deduction under section 80IB - Held that:- We do not find any infirmity or good reason to interfere with the order of Commissioner of Income Tax (Appeals) since the Commissioner of Income Tax (Appeals) has only followed the decision of Hon'ble Supreme Court in the case of Liberty India v. CIT (2009 (8) TMI 63 - SUPREME COURT ) in concluding that duty drawback is not profits derived from industrial undertaking for the purpose of computing relief under sec.80IB of the Act. - Decided against assessee.
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2015 (1) TMI 1274
Whether amendment made by notification dated May 5, 1997 is applicable from the said date itself or it would operate retrospectively from the date of the issuance of the notification amended, i.e., Notification 781 dated May 31, 1995 - Manufacture and sale of electronic goods - Petitioner-revisionist was granted eligibility of certificate for exemption for a period of 10 years - Held that:- It is settled position in law that the taxing statute is generally prospective in nature and if it has to be made retrospectively it has to be specifically provided. There is nothing on record to suggest that the amendment by substitution has been given retrospective step rather the notification dated May 5, 1997 in specific and unequivocally terms recites that the amendment which is being made in the notification dated March 31, 1995 shall come into effect from the date of publication of the notification in the gazette. The said notification in the gazette was admittedly published on May 5, 1997. Therefore, when the notification itself provides for the date of applicability of the aforesaid notification no retrospectivity to it can be attributed so as to apply it from the effective date of Notification No. 781 dated March 31, 1995.
Therefore, the Tribunal as such is not justified in holding that the amendment would be operative from April 1, 1995. Even if it is assumed that there was some mistake in the notification dated March 31, 1995, the said mistake cannot be taken note of. The mistake if any as suggested by the Tribunal was corrected by the notification dated May 5, 1997 and the said mistake would stand rectified from the date of publication of the subsequent notification and would not relate back to the notification dated March 31, 1995. - Decided in favour of assessee
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2015 (1) TMI 1273
Challenge to notification - Contravention of articles 301 and 304(a) of the Constitution of India Seeking grant of concession in tax for local manufacturers - Manufacturers of steel bars and steel structural outside the state - Respondents issued a notification dated March 4, 2014 under section 15B of the VAT Act levying a flat rate of three per cent tax only on steel bars (excluding in coil form) and steel structural under section 14(iv)(iv) and (v) of the Central Act for the period April 1, 2013 to March 31, 2014 - Held that:- it needs no emphasis that subjecting the same goods imported into the State to a higher rate of tax only as compared to those manufactured locally would make the imported goods more expensive making it unviable and uncompetitive. A natural corollary would be that inflow into the State of these goods from outside the State would drop impeding inter-State trade and commerce. It needs no discussion that the manufacturers outside the State shall be put at a disadvantage and will find no takers for their products in the State who will naturally prefer to purchase it from those granted exemption in the State whose price and costs shall naturally be lesser and lower.
No details have been furnished with regard to specified areas, or the number of unit falling in the exempted category situated in the State who have availed of the benefits since it was first introduced on March 30, 2013 and how it has contributed to the economic growth of the State. The respondents have not furnished any data for distinguishing one per cent tax between the two exempted categories of small and medium scale enterprises and an investment limit of 10 lacs. No material has been brought on record that despite grant of exemption manufacturers outside the State have not been put at disadvantage and are continuing to do business. Likewise there is no data with regard to number of industrial units falling outside the exempted category in the State and whether they had been affected or not by the grant of concession. How the exempted category alone had given the desired impetus to industrialisation and how it was necessary to do so and the manner in which it would give a economic boost to the State.
Therefore, the impugned notification to the extent that it puts at a disadvantage manufacturers outside the State from doing business in the State putting them at a competitive disadvantage, contravenes articles 301 and 304(a) of the Constitution. The effect of granting exemption to the specified category of manufacturers only is to raise the rate of tax for manufacturers from outside the State. It is not necessary that this discrimination must be only by a positive act of imposition and it can well be by a negative effect of exemption. The effect of such exemption is to subject the local exempted category to a different rate of tax from those outside the State. It shall be the test of the effect of the exemption which shall be crucial to decide if it impedes free-flow of inter- State trade and commerce.
Challenge to notification for exemption - Manufacturers of steel bars and steel structural within the state who do not fall in the category of small and medium scale industrial unit and have investment beyond ten crores - Those manufacturing the two specified products in the State form a class. Article 14 of the Constitution permits classification but prohibits class legislation - Held that:- there is no intelligible differentia discernible in creation of these two categories of manufacturers and purchasers from them as a separate favoured class having any nexus with any object of quick industrialisation to be achieved by rationale. No empirical data has been placed with regard to the number of units in each of the two exempted categories, or how many of them had closed down and dealerships surrendered in absence of concessions in recent preceding years. The number of industrial units falling outside the exempted categories and that grant of concessions had not affected them in any manner and none had closed down. Levying of a higher rate of tax on other local manufacturers may well sound the death knell for them in the State rendering them unproductive and uncompetetive. Section 15B of the VAT Act has rightly been urged to be applicable to a class of dealers. If all manufacturers of the two products form a class of dealers and there is no rationale for differentiating criteria between them, it violates the constitutional guarantee for equality under article 14 and the notification is liable to be struck down on that ground also. Therefore, the notification dated May 30, 2014 is held to be bad on both counts of contravening articles 301 and 304(a) of the Constitution as also violating the equality clause under article 14 of the Constitution. The notification is therefore struck down. - Decided in favour of petitioner
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2015 (1) TMI 1272
Duty short paid - Demand of interest and penalty under Rule 27 of the Central Excise Rules, 2002 - payment of differential duty - period of limitation - Held that:- Held that:- Under the Central Excise Act, the normal period of limitation for demand of duty short levied or not levied, etc. is one year. Now the question is how does or from what date the said period of one year should be computed. The appellant herein was asked by the Regular Bench to file copies of the monthly excise returns so that it can be ascertained when and whether they had intimated the fact of short payment of duty; however, the appellant was unable to produce copies of the said returns. In the absence of any such evidence led by the appellant, it can be safely presumed that the fact of short payment of duty was brought to the notice of the department only in the monthly returns filed after payment of differential duty. In the present case, it is a fact on record that the short payments were made good only on 30-6-2002 and 6-12-2002 and therefore, these details would be available only in the returns filed in July, 2002 and January, 2003. The show cause notice having been issued in October, 2003, the demand in respect of payment made in December, 2002, is clearly within the normal period of limitation of one year and hence, the demand of interest in respect of this payment is clearly sustainable.
Though a contention has been raised that since the issue pertained to interpretation of the statute, imposition of penalty is not warranted is not agreed for the simple reason that it is not the case of the appellant that he was not liable to pay interest. The only contention is that the notice was not issued in time. It should be remembered that the appellant is operating in a “self-assessment of tax” regime and therefore, a greater responsibility is cast on him to comply with the requirements of law. Rule 27 imposing general penalty does not require any mens rea on the part of the assessee and mere default will suffice to attract its provisions
Thus the interest on the duty paid in December 2002 is upheld. Penalty imposed under Rule 27 for default in payment of interest is also upheld. As far as the interest on the duty paid in May is concerned, the same is set aside.
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2015 (1) TMI 1271
Validity of assessment made on best judgment basis - No records submitted by assessee - Manufacturer of bricks - Held that:- it is the owner of the brick kiln who was in possession of all the books of accounts. The assessee cannot urge that because he has not produced the books of account the assessing officer should not make assessment on best judgment basis. From the record, it is apparent that the assessee had not even filed returns for various periods, but when the taxation inspectors visited the spot they found huge amounts of coal and firewood lying which obviously had to be used for the purpose of production of the bricks. Therefore, the assessing officer has passed a reasoned order.As in appeal, none had appeared before the appellate authority, thereafter, even in the writ petition, none appeared and now the appellant cannot be heard to argue that there is no record available with the Department and therefore, no assessment could have been made. - Decided against the petitioner
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2015 (1) TMI 1270
Addition on account of amortization of premium paid on Government Securities which fall in the category of held to maturity - Held that:- The assessee is entitled to the claim of deduction on account of amortization of premium paid on Government securities held in HTM category. See Commissioner of Income Tax-2, Mumbai Versus HDFC Bank Ltd. [2014 (8) TMI 119 - BOMBAY HIGH COURT ] - Decided in favour of assessee
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2015 (1) TMI 1269
Assignment Agreement - whether assignee of a secured creditor in terms of Section 5(1)(b) of the SARFAESI Act, who steps into the shoes of secured creditor has a right to stand outside the winding up proceedings and still bring the properties mortgaged to sale? - Held that:- There is no bar in handing over the possession of the assets of the company in liquidation to the Asset Reconstruction Company for taking further steps to sell the same. The sale of the assets shall also be got confirmed from the Company Court. The object is to get maximum price for the assets of the company in liquidation.
The contention raised by learned counsel for the shareholders and guarantors for restraining the Asset Reconstruction Company to sell of the assets of the company in liquidation is merely to be noticed and rejected. No provision of law has been pointed out to show as to how validity of assignment agreement can be challenged before the Company Court. Once the debt has been assigned by IFCI to the Asset Reconstruction company, it steps into its shoes as secured creditor and can take whatever action a secured creditor could take. The apprehension of the shareholders and the guarantors was that the assets of the company in liquidation may not be sold at throw away price. The apprehension is misplaced, if considered in the light of the directions already issued in terms of which the Asset Reconstruction company is to associate the Official Liquidator at every stage and further the sale shall be subject to approval by the Company Court. Even at that stage, the applicants- shareholders and guarantors shall be at liberty to intervene and bring a better buyer so as to get the maximum price for the properties sold.
As far as claim of liquidation expenses by the Official Liquidator is concerned, learned counsel for the Asset Reconstruction company has stated that entire amount claimed shall be paid, however, it is directed that the Official Liquidator shall provide the vouchers in support of the claim for the amount paid for valuation of the assets for sale and also for payments made to the security agencies. The amount claimed by the Official Liquidator be paid within one month.
The possession of the assets of the company in liquidation be handed over by the Official Liquidator to the Asset Reconstruction company as early as possible with notice to the shareholders. The inventory of the fixed and moveable assets shall be prepared at the time of handing over the possession to the Asset Reconstruction company. At that time, respondent nos. 8 and 9 shall be at liberty to be present and ensure that correct inventory is being prepared.
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2015 (1) TMI 1268
Revision u/s 263 - AO has allowed excess set off of unabsorbed depreciation - Held that:- We find the order u/s.143(3) has been passed for A.Y. 2006-07 determining the unabsorbed depreciation and business loss that has to be carried forward the details of which are already given at para 4 of the impugned order. Therefore, the mistake, if any, has crept in the order for A.Y. 2006-07 and certainly not in the order for A.Y. 2007- 08. The AO has simply followed the order of his predecessor giving effect to the quantum of brought forward loss to be set off from the income of the current year. Therefore, the order for the impugned assessment year cannot be said to be erroneous although it may be prejudicial to the interest of the revenue.
It has been held in various judicial decisions that for assuming jurisdiction u/s.263 by the Ld.CIT, the twin conditions, i.e. (a) order is erroneous and (b) order is prejudicial to the interest of the Revenue must be satisfied. In the instant case, since the unabsorbed business loss and unabsorbed depreciation loss which has to be carried forward for subsequent years has been quantified in the order passed u/s.143(3) dated 31-12-2008 for A.Y. 2006-07 and since the AO has simply followed that order while giving set off of unabsorbed depreciation loss for the A.Y. 2007-08, therefore, the order in our opinion cannot be said to be erroneous. Thus it is not a fit case for assuming jurisdiction u/s.263 of the I.T. Act. - Decided in favour of assessee
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2015 (1) TMI 1267
Addition on provision for loss on Government Securities - Held that:- The issue arising in the present appeal is identical to the issue decided in in Pune District Central Co. Operative Bank Ltd. Vs. Addl.CIT [2015 (4) TMI 726 - ITAT PUNE ] wherein held in case of banks, the premium paid in excess of face value of investments classified under HTM category which has been amortised over the period till maturity is allowable as revenue expenditure since the claim is as per RBI Guidelines and CBDT also has directed to allow such premium. In view of above, the assessee is justified in contending that the amortization of premium in excess of face value securities as HTM, period remaining difference was found reasonable. Accordingly, the disallowance made by the Assessing Officer claimed as amortization of premium expenditure for HTM securities by payment of premium over and above the face value of such securities is directed to be allowed. Also see CIT Vs. HDFC Bank Ltd [2014 (8) TMI 119 - BOMBAY HIGH COURT] - Decided in favour of assessee
Addition made on account of provision for interest on NPAs - Held that:- Similar issue of allowability of the provision made on account of interest on NPAs, arose before Pune Bench of the Tribunal in the case of Shri Yashwant Sahakari Bank Ltd. Vs. ITO [2014 (4) TMI 1118 - ITAT PUNE] held that the interest on NPA advance cannot be treated as “accrued” to the assessee.- Decided in favour of assessee
Addition towards provision for Standard Assets made as per the guidelines of RBI - Held that:- The issue raised is squarely covered against the assessee by the order of Pune Bench of the Tribunal in The Sindhudurg Dist. Central Co-op Bank Ltd. Vs. ITO [2012 (3) TMI 492 - ITAT PUNE] wherein held that claim for deduction of an expenditure is liable to be governed by the provisions of the Act and not merely on account of the RBI guidelines. In our view, the ratio of the judgment of the Hon’ble Supreme Court the case of Southern Technologies Ltd. (2010 (1) TMI 5 - SUPREME COURT OF INDIA ) clearly applies to the present case and the claim of the assessee has been rightly rejected by the lower authorities - Decided against assessee
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2015 (1) TMI 1266
Recovery of amount of Drawback under Rule 16A of 1995 Rules - Sale proceeds of export not realised - Appellant realized the sale proceeds of exports through LCs and drawback was paid on the over-valued FOB of export revealed the market enquiry as well as and overseas enquiry. Also the importers were not engaged in export and import and preliminary payments received from “000 Business Kant” in Russia were returned back to the said importer - Held that:- as Revenue says that preliminary payments received from “000 Business Kant” have gone back to the account of said concern but there was no enquiry made to ascertain whether any such payments were remitted by appellants only to that concern from India or any arrangement was made in that behalf. Therefore Rule 16A ibid cannot be invoked but the only rule can be invoked was Rule 16 of 1995 Rules.
Confiscation of goods - Under Section 113(d) of Customs Act, 1962 - Held that:- relating to the exports under Debt Repayment Agreement with the erstwhile USSR, export to third country was not allowed and exports were made to countries other than Russia. . Accordingly such exports were made in violation of the instructions issued by the DGFT under para 4.17 of the EXIM Policy, 1997-2002 and Para 2.15 and 2.40 of EXIM Policy, 2002-07, making the exported goods liable to confiscation under Section 113(d) of the Customs Act, 1962 by virtue of Section 11 of the Foreign Trade (Development & Regulation) Act, 1992 read with Section 3(2) & 3(3) of the Foreign Trade (Development & Regulation) Act, 1992. There is also a violation of Rule 11(1) of the Foreign Trade (Regulation) Rules, 1993. Therefore, all these violations rendered the goods to be confiscated being the prohibited goods.
Period of limitation - Absence of the limitation provisions in Rule 16/16A of 1995 Rules - No open ended litigation to perpetuate. It issued original Show Cause Notice on 27-3-2006 and the Addendum on 31-8-2006 for recovery of drawback relating to the period was 1-10-1999 to 10-10-2003 - Held that:- by following the decision of Hon’ble High Court of Gujarat in the case of Pratibha Syntex Ltd. v. Union of India 2013 (3) TMI 480 - GUJARAT HIGH COURT and the decision in the case of Padmini Exports Vs. Union of India 2013 (1) TMI 282 - GUJARAT HIGH COURT, that drawback erroneously paid being recoverable through Rule 16 of 1995 Rules and there is no prescription of any reasonable period, the proceeding is time barred when show cause notice was issued after a reasonable period. Therefore, the Show Cause Notice issued on 27-3-2006 does not appear to be beyond a reasonable period, results in not time-barred.
Imposition of penalty - Held that:- so far as imposition of penalty is concerned mens rea plays a vital role to determine quantum thereof. Therefore, the penalties imposed by the adjudication without stating any reason as to imposition and determination of quantum thereof, appears to be disproportionate, in existence of conflicting evidence on record. - Decided in favour of appellant
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2015 (1) TMI 1265
Rectification of mistake - treating the amounts of interest subsidy and excise duty refund as capital receipts - Held that:- Section 154 has been enacted to enable the authorities to rectify the mistake whether the mistake is done by assessee or by AO. The legislative intent in section 154 is not to allow a mistake to continue. A liberal construction of the statute has to be made else the object of the legislation shall be forfeited. Accordingly, the arguments by Ld. DR cannot help the Revenue. Therefore, in the circumstances and facts of the present case, Hon’ble Jurisdictional Court of J & K in the case of Shree Balaji Alloys reported as (2011 (1) TMI 394 - Jammu and Kashmir High Court ) having held the Excise Duty Refund and Interest Subsidy received by the assessee as capital receipts is a decision subsequent to the decision of AO dated 17.12.2009 where such receipts have been accepted as revenue as returned by the assessee.
Accordingly, in view of the decision in the case of Smt. Arun Luthra (2001 (8) TMI 84 - PUNJAB AND HARYANA High Court ) and Kil Kotagiri Tea and Coffee Estates Ltd. (1988 (7) TMI 54 - KERALA High Court), we are of the view that there is a mistake apparent from record which is rectifiable u/s 154 of the Act and the Ld. CIT(A) has rightly directed the AO to carry out the necessary rectification and the order of the Ld. CIT(A) is found to be well reasoned one and we find no infirmity in the same.
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2015 (1) TMI 1264
Disallowance of the freight and fuel expenses - Held that:- We find that the assessee is into transport business and has 4 trucks. In the preceding assessment year (AY 2007-08), the assessment was carried out u/s 143(3) of the Act, wherein the fuel expenses of ₹ 21,56,080/- was accepted by the department, which worked out to 36.34% of the total receipt of ₹ 59,31,687/-. In the instant year, the assessee claimed freight/fuel/other charges of ₹ 21,92,980/-, when the total receipt was ₹ 61,44,530/- which works out to 35.69% only. When the department has accepted the expenditure of 36.34% in AY 2007-08, in that year, so when the expenses is less i.e. 35.69% in this year, the ad hoc disallowance without bringing in comparable cases is not justified. Moreover, as per section 44AE, the income from four trucks works out to ₹ 1,64,000/- whereas the assessee has declared an income of ₹ 5,93,612/- which puts the assessee’s case in a better position; and the assessee’s contention that taking into consideration the transport business carried out by the assessee, wherein expenses are incurred for which no bills can be obtained always, cannot be ruled out. So we find force in the argument of the ld. AR, that in the aforesaid facts and circumstances and considering the previous year results too, the ad hoc disallowance was not warranted. So we direct deletion of the addition - Decided in favour of assessee
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2015 (1) TMI 1263
Rejection of refund claim before reassessment - Assessment of Bill of Entry took place on 22.02.2011 and the appellant sought amendment in Bill of Entry on 24.02.2011 for which the reassessment of Bill of entry was sought by the appellant and rejected by the revenue - Held that: the refund claim as claimed by the appellant was not required to be rejected before reassessment of the Bill of Entry as sought by the appellant. Therefore, the matter remanded back to the Adjudicating Authority to decide the reassessment of Bill of Entry. - Matter remanded back
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2015 (1) TMI 1262
Cassification - Supply of tangible goods service under Section 65(105)(zzzj) of Finance Act, 1994 - An agreement was entered by the appellant, which shows ‘Right of possession' was with the lessee, the appellant, during the contract period - Held that: By relying on the Tribunal's Judgment in case of Petronet LNG Ltd. Vs. CST 2013 (11) TMI 1011 - CESTAT NEW DELHI, the transactions fall within the ambit of the exclusionary clause of Section 65(105) (zzzzj) of the Act. - Decided against the revenue
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2015 (1) TMI 1261
Recovery proceedings initiated by the Customs authorities after a period of more than eight years from the completion of the export transaction - validity of issuance of show cause notice - Period of limitation - Held that:- Since it is evident that no notice was issued by the department to the first petitioner within five years of February, 2005, the steps taken by the respondent authorities to recover the duty exemption afforded to the first petitioner cannot be permitted to continue. The show-cause notice dated July 11, 2011, a copy whereof appears as Annexure P-8 to the petition at page 60 thereof, is set aside as being without jurisdiction. As a consequence, all steps taken pursuant to the show cause notice, including the order-in-original dated February 26, 2014, are also set aside. - Decided in favor of petitioners.
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2015 (1) TMI 1260
Condonation of delay in filing an appeal - it was contended that appellant came to know about the passing of the order when the Revenue approached them for recovery proceedings - Held that:- The order impugned in the present appeal was admittedly received by the appellant on 04.07.2012 read with the corrigendum received on 19.07.2012. Even if the date of receipt of corrigendum is considered to be the relevant date, instead of considering the receipt of the impugned order on 04.07.2012, the last date for filing appeal expired on 18.10.2012. As per the appellant themselves, their Manager (Finance), who was looking after the tax matters was in their service till 1st October 2012 i.e., he left the job only a few days prior to the expiry of the last date. Even during that period of two and half months or more, the appellants have not taken any steps to get the appeal prepared. No evidence that they were taking any steps to file the appeal stand produced before us.
As such, even if the appellant’s plea that they came to know about the passing of the impugned order only when the said letter was received by them is accepted, even then there is a delay of more than 6 months in filing the present appeal. The said letter was received by the appellant on 20.12.2012, clearly indicating that the order of the Commissioner is appealable before Tribunal. Even then the appeal was filed on 17.06.2013 i.e. after a period of about 6 months, without giving any reasonable cause for such a huge delay of 6 months in filing the present appeal. - Condonation denied - Decided against the assessee.
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2015 (1) TMI 1259
Interest on licence fee paid to DoT Government of India disallowed - Held that:- We confirm the finding arrived at by the CIT(A to the extent that the interest accrued on delayed payments on the license fee is a capital expenditure u/s 35ABB since the payment was for the period prior to 31.07.1999. - Decided against assessee
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2015 (1) TMI 1258
Service tax on GTA - reverse charge - each of the consignment note issued by the respective Transporters did not bear the declaration of non-availment of CENVAT Credit and also the benefit under Notification No.12/03-ST dated 20.06.2003 on the face of it - Held that:- the declarations filed by the goods transport agencies (GTA) in their letter-heads or in the respective payment bills certifying that they have not availed CENVAT Credit on inputs or capital goods nor availed the benefit of exemption Notification 12/2003-ST dated 20-06.2003 should have been accepted by the department - Matter remanded back.
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