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Showing 261 to 280 of 2063 Records
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2019 (1) TMI 1807
Sanction of Scheme of Merger (by absorption) - Sections 230 to 232 of the Companies Act, 2013 - HELD THAT:- The Fourth Applicant / Transferee Company is accordingly directed to serve notices along with the documents as mentioned (a) the draft of the proposed terms of the Scheme drawn up and adopted by the Board of Directors; (b) confirmation that a copy of the draft Scheme has been filed with the Registrar; (c) a report adopted by the Directors of the Applicant Companies explaining the effect of the amalgamation on each class of shareholders, key managerial personnel, promoters and non-promoter shareholders laying out in particular the share exchange ratio, specifying any special valuation difficulties; (d) the report of the expert with regard to valuation, if any; (e) a supplementary accounting statement, if any, if the last annual accounts of any of the merging companies relate to a financial year ending more than 6 months before the date of service of notice, upon:- (i) concerned Income Tax Authority with in whose jurisdiction the Transferee Company’s assessments are made, (ii) the Central Government through the office of Regional Director, Western Region, Mumbai, (iii) Registrar of Companies, Mumbai (iv) BSE Limited (v) National Stock Exchange of India Limited (NSE) with a direction that they may submit their representations, if any, within a period of thirty days from the date of receipt of such notice to the Tribunal with copy of such representations shall simultaneously be served upon the Applicant Company, failing which, it shall be presumed that the authorities have no representations to make on the proposals.
The Applicant Companies to file affidavit of service in the Registry proving dispatch of notices to the shareholders and Creditors, publication of notices in newspapers and service of notice to the regulatory authorities as stated above and do report to this Tribunal that the directions regarding the issue of notices have been duly complied with.
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2019 (1) TMI 1806
Time Limitation for issuance of SCN - Extension of time for issuance of Show Cause Notice - amended provisions of Section 110(2) of Customs Act - HELD THAT:- Similar issue has come before Hon’ble Tribunal in case of HARBANS LAL VERSUS COLLECTOR OF CENTRAL EXCISE & CUSTOMS [1993 (7) TMI 76 - SUPREME COURT] wherein it is held that two Sections 110 and 124 are independent, distinct and exclusive of each other resultantly in the reviewing the proceedings of Section 124 in case itself with the seized goods might have been return or has been returned in terms of Section 110 of the Customs Act after the expiry of permissible seizure.
Reliance placed in the case of Sardar Kulwant Singh vs. Collector of Central Excise and Customs [1980 (10) TMI 62 - HIGH COURT OF DELHI AT NEW DELHI], wherein it is held that an order extending period of issue of Show Cause Notice under Section 110(2) and 124 of the Customs Act, 1962, without giving an opportunity of being heard to the affected party is illegal. Further, the requirement of issue of Show Cause Notice issued under Section 124 of the Customs Act in such a case was held to be a must relying upon the various judgments referred as above. Relying on these judgments, we find that the seized goods are required to be returned to the person from whom the seizure has been made of fact of expiry of six month under Section 110 of the Act without extension of time - Regarding the Revenue contention that with effect of the amendment carried out in Section 110(2) of the Customs Act, the requirement of issuance of Show Cause Notice is dispensed with is without any basis - Careful analysis of the provision makes it clear that the right of issuance of the Show Cause Notice for the extension of the period of six months as prescribed under said sub-Section of Section 110(1) remains same from which the emanate right of Show Cause Notice to the affected party in furtherance of Principle of Natural Justice as his rights are being prejudicially affected. The amendment will not obliterate the aforesaid position of issuance of Show Cause Notice has discussed above, even after insertion of with new sentence in the provisions of Section 110(2) of the Act.
In fact, after amendment not only the Show Cause Notice is required to be issued by the Adjudicating Authority, but he has also to give a reasoned order after hearing the Investigation Officer and also taking view of the affected party from whom seizure has been made as his personal right is being deprived of which emanate from the Section 110(1) of the Act that entitled him to got the goods returned which has been seized from his possession.
The impugned order is in violation in this provisions of Section 110 of the Customs Act - Appeal allowed - decided in favor of appellant.
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2019 (1) TMI 1805
Deduction of service charges paid to the employees - bogus claim as the employees, who were examined by the AO had denied having received any service charges - HELD THAT:- What is paid to the employees is only out of the amount collected from the customers in the form of the service charges but the total service charges paid to the employees far exceeds the amount collected. This fact undoubtedly raises doubts as to the genuineness of the claim made. Perhaps, this would have triggered the AO to enquire into the genuineness of the claim. As a part of inquiry into the claim, the AO had examined certain employees, who had denied having received any such service charges. However, this would not lead to a conclusion that the claim is untenable in view of the fact that the employees, who were examined by the AO may not be working during that relevant time.
Onus of proving the claim always lies on the assessee. But, the present case, the assessee-company failed to lead any evidence to prove the claim.
CIT(A) had merely based on the presumptions that the assessee-company would have paid to the employees to the extent of the service charges collected and allowed the claim to the extent of service charges collected. Further, the ld. CIT(A) had not even examined whether the service charges are really collected by the assessee-company nor was any evidence was discussed in the order in support of the claim for the expenditure. CIT(A) had proceeded on assumptions and presumptions while granting the partial relief. Order of the ld. CIT(A) is also not supported by any material on record. CIT(A) also failed to note that the facts necessary to prove the claim would be within knowledge of the assessee and it is the duty of the assessee alone to prove that what is claimed is true and correct
AO was justified in drawing adverse inference on the claim and the ld. CIT(A) ought not have granted any relief in the absence of any evidence in support of the claim. Therefore, the appeals filed by the assessee are dismissed and the appeals filed the Revenue are allowed.
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2019 (1) TMI 1804
Validity of the orders passed by the Government in G.O.Ms.No.181, dated 11.7.2011 - constitution of fresh committee with the Chief Secretary as Chairperson and with some other members for the purpose of suggesting the factors to be considered while fixing or increasing the rates of tickets in various classes of Cinema Theatres.
HELD THAT:- Petition disposed off.
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2019 (1) TMI 1803
Jurisdiction - validity of SCN - Works Contract or not - contract for designing, supplying and installing Modern Kitchens / Wardrobes - HELD THAT:- The issue involved in the present writ petition is squarely covered by the decision of the Hon'ble Supreme Court in M/S. KONE ELEVATOR INDIA PVT. LTD. VERSUS STATE OF TAMIL NADU AND OTHERS [2014 (5) TMI 265 - SUPREME COURT], wherein the Hon'ble Supreme Court remitted the matter to the authorities with a direction to look into the contract entered into between the parties and thereafter decide the nature of the transactions. Hence the impugned assessment order is set aside and the matter is remitted to the respondent for passing fresh order, within a period of six weeks from the date of receipt of a copy of this order.
Petition allowed by way of remand.
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2019 (1) TMI 1802
Maintainability of application - initiation of CIRP - Operational Creditor or not - any goods or services not supplied - HELD THAT:- The respondent submitted that the work order was a joint venture for which the respondent also invested 50% money and 50% of the same was payable to the ‘corporate debtor’. If that be so and we accept, as suggested by the learned counsel for the appellant that the respondent invested an amount for the joint ventur,e then in that case the respondent can claim as the ‘financial creditor’ and not as ‘operational creditor’.
The respondent is not an ‘operational creditor’, and, therefore, the application under Section 9 was not maintainable.
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2019 (1) TMI 1801
Impleadment of petitioner - financial scam - HELD THAT:- On perusal of the record of CP 277/2018 and charge sheet ,which has been filed by CBI against the proposed Respondents, in connection with the case relating to Mr. Nirav Modi and Mr. Mehul Chokshi, it appears that proposed respondents are necessary and proper parties to the original Company petition and as such, it is essential they be arrayed as R70 to R88 in Company petition No.277/2018 - the Petitioner are directed to implead the proposed respondents as R70 to R88 with immediate effect.
It is pertinent to mention that when at the initial stage when the stay was granted only FIR was registered but now the position has changed after CBI has filed the charge sheet against the proposed R70 to R88, in connection with the case relating to Mr Nirav Modi and Mr Mehul Choksi financial scams - It is to be clarified that the stay order has already been passed against R1 to R67 which has been further modified to a certain extent by order of Hon’ble NCLAT which is effective today. Therefore, an extension of the order dated 23.2.2018 passed by this Tribunal further modified by Hon’ble NCLAT is essential to R70 to R88.
Application disposed off.
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2019 (1) TMI 1799
Principles of Natural Justice - case of petitioner is that the first respondent did not give any personal hearing or notice before passing the impugned order - Recovery of possession of property - HELD THAT:- The fact that the appellant's name was in the revenue records before the modification of entry by the impugned order passed by the first respondent is not in dispute. In such circumstances, even for carrying out any correction, the person, against whom the entry is made, should be given an opportunity before the modification of entry is made. In this case, it is not in dispute that the appellant was not given any opportunity by the first respondent before passing the impugned order. Admittedly, no notice was issued to the appellant before passing the impugned order. The fact that the second respondent, namely, the Tahsildar, conducted an enquiry and submitted a report before the first respondent and on the basis of the said report, the first respondent passed the impugned order will indicate that the impugned order in writ petition is in violation of principles of natural justice.
The matter is remitted to the first respondent for fresh hearing and the first respondent shall pass an order after affording sufficient opportunity to both appellant as well as the third respondent and consider their case on merits - Petition allowed by way of remand.
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2019 (1) TMI 1798
Evasion of SAD - warehousing of goods with intent to evade Additional Duty of Customs leviable under Sub-section (5) of Section 3 of Customs Tariff Act, 1975 - HELD THAT:- There are no reason to interfere in the impugned order inasmuch as this Tribunal has already held in the case of M/S LLOYD ELECTRIC & ENGINEERING LTD., ZAMIL AIR CONDITIONERS PVT. LTD. VERSUS COMMISSIONER OF CUSTOMS, CENTRAL EXCISE & SERVICE TAX [2018 (3) TMI 567 - CESTAT ALLAHABAD] that the present appellants were helping the importers in evasion of said SAD by allowing them to warehouse goods in their warehouse and subsequently allowing clearances of the same without payment of said SAD.
Appeal dismissed - decided againsy appellant.
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2019 (1) TMI 1797
Penalty u/s 271AAB - undisclosed income - Invalid notice u/s 274 - proper explanation and disclosure was given during the course of search action in the statement recorded u/s. 132(4) and the disclosure so made was offered to tax in the return of income filed - HELD THAT:- Assessee with the panel provisions, it is pre-requisite that it should be evident from the notice, the intend and purpose for levying penalty as the purpose of the notice is to inform the assessee as to the specific charge for which he has been show caused so that he could furnish his reply without any confusion and to the point. In the present case, neither the assessee nor anyone else could make out as to whether the notice u/s. 274 r.w.s. 271 of the Act was issued for concealing the particulars of income or for furnishing inaccurate particulars of such income disabling it to meet with the case of the Assessing Officer. There are a catena of judgments highlighting the necessity for identifying the charge for which the assessee is being visited and in all those decisions, Hon'ble Courts have repeatedly held that where the jurisdictional notice is vague, similar to the one in the present case, the consequent levy cannot be sustained.
The Hon’ble jurisdictional High Court in the case of CIT v. Samson Perinchery [2017 (1) TMI 1292 - BOMBAY HIGH COURT] had also occasion to consider a similar issue. In this case, though proceedings u/s. 271(1)(c) of the Act were initiated for furnishing of inaccurate particulars of income, in the notice issued u/s. 274 r.w.s. 271 of the Act in the standard form, the charge for which it was issued was also not identified, as in the present case.
We hold that the notice issued u/s 274 r.w.s 271 and incorporated 271AAB (in hand) was not valid. Consequently, the penalty proceedings are also invalid. Since the very basis of levy of penalty has been held to be invalid, we are of the view that the other grounds of appeal raised by the assessee against the merits of the levy of penalty requires no adjudication at this stage - Decided in favour of assessee.
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2019 (1) TMI 1796
Disallowance u/s 14A - computing the average value of investment for the purpose of disallowance u/s 14A which are incapable of yielding tax free income - HELD THAT:- AO cannot adopt the average value of the total investment instead of the average value of investment of which income is not part of a total income i.e. value of tax exempt investment. In view of this binding precedent, we find that the AO had to consider only those investments which have actually yielded the tax exempt income during the relevant year and not the total investment.
On the aspect of the contention of the assessee that the disallowance should be restricted to some reasonable proportion of actual dividend received and such disallowance cannot in any case, exceed exempt dividend income earned during the relevant year , this proposition is based on the decision Joint Investments P. Ltd. vs CIT [2015 (3) TMI 155 - DELHI HIGH COURT] as holds the field and while respectfully following the same, we find that the disallowance shall not exceed the exempt income.
Set aside the issue and remand the matter to the file of the learned AO to work out the disallowance by calculating the average investment under Rule 8D(2)(ii)/(iii) by taking only those investments which have actually yielded the dividend income during the relevant year and if it exceeds the exempt income, then restrict the same to the extent of exempt income only. Ground Nos. 1 and Additional Grounds are allowed for statistical purposes.
Disallowance of prior period expense - according to the assessee, this payment was audit fee payable to statutory auditor, namely Price Waterhouse Cooper and the expenses are pertaining to the year under consideration only on which the assessee had duly deducted the tax at source - CIT(A) found that there is inherent contradiction in the stand taken by the assessee inasmuch as according to him, there was payment of TDS on the payments made to the auditor and disallowance u/s 40( a) (ia) while computing the taxable income - HELD THAT:- No reason to interfere with the findings of learned CIT(A) and it is not substantiated before us as to how the findings of the learned CIT(A) are incorrect. We, therefore, uphold the findings of the learned CIT(A).
Short credit of TDS - CIT(A) recorded that the assessee submitted an application for rectification and it was still pending - HELD THAT:- Learned CIT(A) directed the AO to allow the claim after proper verification.
Claim of the brought forward loss and depreciation - CIT(A) directed the learned AO to allow the same after proper verification - HELD THAT:- We do not find anything illegal or irregular in these directions of the learned CIT(A).
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2019 (1) TMI 1795
TP Adjustment - comparable selection - HELD THAT:- Accentia Technologies Ltd. is engaged in the business of developing software products and it does have any segmental information for its services segment and software products segment. Though the Ld D.R sought time to find out availability of segmental details, yet no such information was provided before us. Accordingly, the absence of segmental information would make this company incomparable. Accordingly, we direct the Assessing Officer to exclude this company.
E-clerx Services Ltd. cannot be compared with assessee being a KPO company.
M/s. Mold-Tech Technologies Limited is a KPO company providing structural engineering services. Further during the year under consideration, extra ordinary events like amalgamation and demerger have taken place. Hence, there is merit in the contentions of the assessee that this company cannot be taken as a comparable.
M/s. Acropetal Technologies Limited comparable has two segments namely engineering design service segment and Information technology service segment.TPO has considered engineering design service segment and compared the same with the assessee company. As noticed earlier the assessee company is providing routine ITE services to its AEs as a captive service provider. Identical scenario was considered in the case of Symphony Marketing Solution India P. Ltd. [2014 (2) TMI 83 - ITAT BANGALORE] and this comparable has been excluded.
Since all the above said four companies have been directed to be excluded, arithmetic mean margin of comparable requires to be redetermined and it also requires to be seen as to whether any addition, if any, is called for or not. Accordingly, we restore the issue of determining mean margin of comparables to the file of the Assessing Officer for examining it afresh by excluding four comparable companies.
Disallowance u/s 14A - A.R submitted that the disallowances made while computing the profits and gains of business shall also be eligible for deduction u/s 10A - prayed that the AO may be directed to allow deduction u/s 10A of the Act in respect of disallowance made u/s 14A - HELD THAT:- This claim of the assessee requires examination in terms of the circular issued by CBDT. Accordingly, we restore this issue to the file of AO for examining the same.
Claim for credit of TDS amount - HELD THAT:- We restore this issue also to the file of the AO, as it requires examination of relevant TDS certificates and income declared by the assessee.
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2019 (1) TMI 1794
Maintainability of application - application filed before the Session Judge in the criminal appeal filed by him against the conviction order - power to take additional evidence - Section 391 Cr.P.C. - whether the Session Judge committed error in not exercising power under Section 391 Cr.P.C. to permit the appellant to lead additional evidence? - HELD THAT:- Power to take additional evidence under Section 391 is, thus, with an object to appropriately decide the appeal by the Appellate Court to secure ends of justice. The scope and ambit of Section 391 Cr.P.C. has come up for consideration before this Court in Rajeswar Prasad Misra Vs. State of West Bengal and Another, [1965 (5) TMI 35 - SUPREME COURT]. Justice Hidayatullah, speaking for the Bench held that a wide discretion is conferred on the Appellate Courts and the additional evidence may be necessary for a variety of reasons. He held that additional evidence must be necessary not because it would be impossible to pronounce judgment but because there would be failure of justice without it.
There are no fetters on the power under Section 391 Cr.P.C. of the Appellate Court. All powers are conferred on the Court to secure ends of justice. The ultimate object of judicial administration is to secure ends of justice. Court exists for rendering justice to the people.
Whether present was the case for exercise of the power by the Appellate Court under Section 391 Cr.P.C. to permit adducing the additional evidence at the appellate stage? - HELD THAT:- The trust is admittedly the owner of agricultural land in Village Bichaie. The complainant has been in possession of large number of agricultural lands as thekedar of the trust since 1975, according to his own case, which he even mentioned in the First Information Report. The application under Section 391 Cr.P.C. was made in the Appellate Court to accept certified copy of the Trust Deed dated 18.10.1989 and the Resolution No. 112 dated 18.10.1989 and permitting the appellant to prove the said document by leading oral evidence.
When the Appellate Court has been given power to lead additional evidence, the observation that it is belated stage was uncalled for. Appellant was convicted on 07.10.2013 and appeal was immediately filed on the next date, i.e. 08.10.2013. It was not even mentioned by the High Court that there is anything on record to indicate that appeal was being heard and at this stage the application under Section 391 Cr.P.C. was filed, calling the application as filed at belated stage itself was unjustified. Further, the observation of the High Court that application was filed with some ulterior malafide motive also does not commend us. The appellant had already been convicted by the trial court, the charge was cheating the complainant with regard to sale of agricultural land of the trust. The second Trust Deed dated 18.10.1989, which was on record and referred to by the trial court and was refused to look into on the ground that it was not proved by the appellant. Filing of the application before the High Court to accept the certified copy of the Trust Deed and the Resolution and permit the appellant to lead evidence can in no manner be said to be malafide motive of the accused, who had been convicted in the appeal, has right to take all the grounds and also lead additional evidence, which in accordance with the Appellate Court is necessary in deciding the appeal.
Thus, Appellate Court committed error in not exercising jurisdiction under Section 391 Cr.P.C. in accepting the second Trust Deed dated 18.10.1989 and the Resolution No.112 dated 18.10.1989 and refusing the appellant to lead evidence to prove the documents.
Appeal allowed.
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2019 (1) TMI 1793
Deemed dividend addition u/s 2(22)(e) - ‘payment’ made by the assessee-company to its subsidiary during the previous year - Tribunal confirming the deletion of the entire addition - HELD THAT:- We find that this issue was threadbare analysed by the CIT(A) in his order after calling for a remand report. This finding recorded by the CIT(A) was correct, as there is no payment made by the assessee-company to its subsidiary during the previous year, relevant to the assessment year 2004-05 within the meaning of Section 2(22)(e) of the Act.
Thus, we find that the first appellate authority as well as the Tribunal has considered the factual position and granted relief to the assessee. Thus, we find there is no substantial question of law arising for consideration.
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2019 (1) TMI 1792
Revision u/s 263 - provision for warranty - Tribunal quashing the revision order of CIT-A - HELD THAT:- Provision made on the basis of turnover on same or similar percentage year after year follows a rationale and scientific method of making a provision for such warranty. The actual claims made by the customers against such warranty provision cannot be the sole criteria, to be labelled as the scientific method, as contended by the Revenue, before us. It is the consistency and the commercial prudence of the assessee, in which the assessee chose to make a provision for warranty based on his total turnover figure, which cannot be said to be unscientific, by any stretch of imagination. Such decisions, taken in normal commercial prudence, cannot be interfered with or superseded by the tax authorities.
Tribunal was perfectly justified in holding that the revisional proceedings under section 263 of the Act in such circumstances were not at all justified. Accordingly, we answer the question of law, framed above, in favour of the assessee
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2019 (1) TMI 1791
Late filing of fees u/s.234E - intimation u/s.200A - at what point of time chargeability of levying fees can be done even prior to the amendment was effected i.e.1.06.2015? - HELD THAT:- Prior to 01.06.2015, there was no enabling provision of section 200A of the Act for making adjustment in respect of the statement filed by the assessee with regard to tax deducted at source by levying fee under section 234E - AO has exceeded his jurisdiction in levying fee u/s.234E while processing the statement and made adjustment u/s.200A of the Act which is not justified. Thus while processing statement under section 200A the AO cannot make any adjustment by levying fee under section 234E prior to 01.06.2015. Therefore, fee levied by the AO under section 234E of the Act while processing the statement of tax deducted at source was beyond the scope of adjustment provided under section 200A of the Act and be deleted the same the eye of law.
The Amritsar Bench of the Tribunal in the case of Sibia Healthcare [2015 (6) TMI 437 - ITAT AMRITSAR] has opined that the matter in question was if the fees u/s.234E in respect of defaults in furnishing TDS statement could be levied in intimation u/s.200A of the Act so far as period prior to 1.06.2015 was concerned. It was held that the impugned levy of fee u/s.234E was unsustainable in law.
On perusal and analyzing the details , it is absolutely clear that prior to 1.6.2015, there was no enabling provision in section 200A of the Act for raising a demand in respect of levying fee u/s.234E of the Act. Therefore, we hold that the intimation u/s.200A of the Act as confirmed by the Ld. CIT so far as levying of fees u/s.234E of the Act is, therefore, set aside and the fees levied is deleted. Ground raised by the assessee is allowed.
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2019 (1) TMI 1790
Refund of moneys which are due and payable under the impugned order of the National Consumer Disputes Redressal Commission - HELD THAT:- The closed and the execution proceedings before the NCDRC shall stand withdrawn. In the event of default, the appellant shall lose the benefit of this order and the order passed by the NCDRC shall stand.
Appeal disposed off.
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2019 (1) TMI 1789
Commercial or Industrial Construction Service (CICS) - composite contracts for fabrication and erection of sliding gates, rolling shutters, etc., on Works Contract - period involved is from 16.06.2005 to 30.09.2006 - HELD THAT:- The appellant has, all throughout, right from the reply to the Show Cause Notice, been maintaining that the activity done by them would fall under Works Contract Service. We find from paragraph 1 of the Show Cause Notice dated 06.01.2009, that the same also acknowledges that the appellant “had undertaken composite contracts of supply/erection of the said items - the ratio laid down by the Hon’ble Apex Court in the case of COMMISSIONER, CENTRAL EXCISE & CUSTOMS VERSUS M/S LARSEN & TOUBRO LTD. AND OTHERS [2015 (8) TMI 749 - SUPREME COURT] will apply on all fours to the case on hand where it was held that Works contract were not chargeable to service tax prior to 1.6.2007.
Appeal allowed - decided in favor of appellant.
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2019 (1) TMI 1788
Refund of the excess duty paid - assessment not challenged before claiming the refund of excess duty - HELD THAT:- The issue decided in the case of AMAN MEDICAL PRODUCTS LTD. VERSUS COMMISSIONER OF CUSTOMS, DELHI [2009 (9) TMI 41 - DELHI HIGH COURT] where it was held that the refund claim of the appellant was maintainable under Section 27 of the Customs Act and the non-filing of the appeal against the assessed bill of entry does not deprive the appellant to file its claim for refund under Section 27 of the Customs Act, 1962.
Appeal is remanded to the adjudicating authority, who is directed to process the refund claim on merits - appeal allowed by way of remand.
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2019 (1) TMI 1787
Maintainability of appeal - Mixed questions of fact and law - appellant challenged the order of assessment under Section 143(3) - HELD THAT:- Admittedly, as against the order of assessment under Section 143(3) of the Act, an appeal lies to the Commissioner of Income Tax (Appeals) [for brevity, the CIT (A)] in terms of Section 246A of the Act. In our considered view, the appellant should not have by-passed the remedy, as the issues involved in the instant case are mixed questions of fact and law, which, obviously, a Writ Court cannot go into.
Maintainability is an issue between the appellant/writ petitioner and the Court. Therefore, the Court will be well justified in refusing to entertain the matter, for which, the concession or consent of the respondent is unnecessary.
We grant permission to the appellant to withdraw the said writ petition as well as this appeal. We also grant liberty to the appellant to file the appeal before the CIT(A) having jurisdiction over the matter. Accordingly, the writ petition as well as the writ appeal are dismissed as withdrawn.
We grant 30 days' time from the date of receipt of a copy of this judgment to file the appeal before the CIT(A) after taking note of the fact that immediately after the assessment was over and the notice was received, the appellant moved the Writ Court.
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