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Showing 281 to 300 of 1328 Records
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2014 (4) TMI 1049
Disallowance of depreciation claimed on leased plant& machinery - Held that:- When the income was received from leasing out of plant and machinery; on the said rental income the assessee shall be eligible inter-alia to claim deductions u/s 32(1) of the Act. In the light of the express provisions of the Act, the assessee is entitled to claim depreciation on plant and machinery. Since, there is no dispute on the fact that the assessee owns the asset and had rented out the said assets, i.e., plant and machinery and the rental income has been duly brought to tax by the assessee, the assesse is entitled to depreciation. In the light of express provision of law, disallowance made of ₹ 89,52,989/- representing depreciation on plant and machinery has been rightly deleted by the ld CIT(A) and the impugned order is valid in the eyes of law and we confirm the same - Decided against Revenue.
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2014 (4) TMI 1048
Validity of auction sale - Period of limitation to file appeal - whether the High Court could have ignored the settled law that under Article 127 of the Limitation Act, 1963 an application to set aside a sale under Order XXI Rule 89, CPC has to be filed within 60 days from the date of sale and same is the period for making the required deposit - Held that:- A careful perusal of the provisions in Rules 89 and 92 of Order XXI, CPC and Article 127 of the Limitation Act leaves no manner of doubt that although Order XXI Rule 89, CPC does not prescribe any period either for making the application or the required deposit, Article 127 of the Limitation Act now prescribes 60 days as the period within which such an application should be made. In absence of any separate period prescribed for making the deposit, as per judgment of the Constitution Bench in the case of Jammlu Ramulu (2001 (8) TMI 1371 - SUPREME COURT OF INDIA) the time to make the deposit and that for making the application would be the same. - High court committed grave error of law in not noticing the relevant provisions of CPC and the Limitation Act and in allowing the Writ Petition for re-consideration of the petition under Order XXI Rule 89, CPC. In absence of required deposit made by the judgment-debtor within the time mandated by law, such an exercise would be only an exercise in futility because the Executing Court does not have any option but to reject the petition. In such a situation, the judgment under appeal is set aside - Decided in favour of appellant.
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2014 (4) TMI 1047
Application to seek a legal declaration of their gender identity than the one assigned to them, male or female, at the time of birth and their prayer is that non-recognition of their gender identity violates Articles 14 and 21 of the Constitution of India - Held that:- Following the trend, in the international human rights law, many countries have enacted laws for recognizing rights of transsexual persons, who have undergone either partial/complete SRS, including United Kingdom, Netherlands, Germany, Australia, Canada, Argentina, etc. United Kingdom has passed the General Recommendation Act, 2004, following the judgment in Christine Goodwin (supra) passed by the European Courts of Human Rights. The Act is all encompassing as not only does it provide legal recognition to the acquired gender of a person, but it also lays down provisions highlighting the consequences of the newly acquired gender status on their legal rights and entitlements in various aspects such as marriage, parentage, succession, social security and pensions etc. One of the notable features of the Act is that it is not necessary that a person needs to have undergone or in the process of undergoing a SRS to apply under the Act.
The Act defines certain characteristics to be “protected characteristics” and no one shall be discriminated or treated less favourably on grounds that the person possesses one or more of the “protected characteristics”. The Act also imposes duties on Public Bodies to eliminate all kinds of discrimination, harassment and victimization. Gender reassignment has been declared as one of the protected characteristics under the Act, of course, only the transsexuals i.e. those who are proposing to undergo, is undergoing or has undergone the process of the gender reassignment are protected under the Act.
Social exclusion and discrimination on the ground of gender stating that one does not conform to the binary gender (male/female) does prevail in India. Discussion on gender identity including self-identification of gender of male/female or as transgender mostly focuses on those persons who are assigned male sex at birth, whether one talks of Hijra transgender, woman or male or male to female transgender persons, while concern voiced by those who are identified as female to male trans-sexual persons often not properly addressed. Female to male unlike Hijra/transgender persons are not quite visible in public unlike Hijra/transgender persons. Many of them, however, do experience violence and discrimination because of their sexual orientation or gender identity.
Non-recognition of the identity of Hijras/transgender persons denies them equal protection of law, thereby leaving them extremely vulnerable to harassment, violence and sexual assault in public spaces, at home and in jail, also by the police. Sexual assault, including molestation, rape, forced anal and oral sex, gang rape and stripping is being committed with impunity and there are reliable statistics and materials to support such activities. Further, non- recognition of identity of Hijras /transgender persons results in them facing extreme discrimination in all spheres of society, especially in the field of employment, education, healthcare etc. Hijras/transgender persons face huge discrimination in access to public spaces like restaurants, cinemas, shops, malls etc. Further, access to public toilets is also a serious problem they face quite often. Since, there are no separate toilet facilities for Hijras/transgender persons, they have to use male toilets where they are prone to sexual assault and harassment. Discrimination on the ground of sexual orientation or gender identity, therefore, impairs equality before law and equal protection of law and violates Article 14 of the Constitution of India.
Articles 15 and 16 sought to prohibit discrimination on the basis of sex, recognizing that sex discrimination is a historical fact and needs to be addressed. Constitution makers, it can be gathered, gave emphasis to the fundamental right against sex discrimination so as to prevent the direct or indirect attitude to treat people differently, for the reason of not being in conformity with stereotypical generalizations of binary genders. Both gender and biological attributes constitute distinct components of sex. Biological characteristics, of course, include genitals, chromosomes and secondary sexual features, but gender attributes include one’s self image, the deep psychological or emotional sense of sexual identity and character. The discrimination on the ground of ‘sex’ under Articles 15 and 16, therefore, includes discrimination on the ground of gender identity. The expression ‘sex’ used in Articles 15 and 16 is not just limited to biological sex of male or female, but intended to include people who consider themselves to be neither male or female.
Gender identity, therefore, lies at the core of one’s personal identity, gender expression and presentation and, therefore, it will have to be protected under Article 19(1)(a) of the Constitution of India. A transgender’s personality could be expressed by the transgender’s behavior and presentation. State cannot prohibit, restrict or interfere with a transgender’s expression of such personality, which reflects that inherent personality. Often the State and its authorities either due to ignorance or otherwise fail to digest the innate character and identity of such persons. We, therefore, hold that values of privacy, self-identity, autonomy and personal integrity are fundamental rights guaranteed to members of the transgender community under Article 19(1)(a) of the Constitution of India and the State is bound to protect and recognize those rights.
Article 14 has used the expression “person” and the Article 15 has used the expression “citizen” and “sex” so also Article 16. Article 19 has also used the expression “citizen”. Article 21 has used the expression “person”. All these expressions, which are “gender neutral” evidently refer to human-beings. Hence, they take within their sweep Hijras/Transgenders and are not as such limited to male or female gender. Gender identity as already indicated forms the core of one’s personal self, based on self identification, not on surgical or medical procedure. Gender identity, in our view, is an integral part of sex and no citizen can be discriminated on the ground of gender identity, including those who identify as third gender.
Discrimination on the basis of sexual orientation or gender identity includes any discrimination, exclusion, restriction or preference, which has the effect of nullifying or transposing equality by the law or the equal protection of laws guaranteed under our Constitution, and hence we are inclined to give various directions to safeguard the constitutional rights of the members of the TG community - Hijras, Eunuchs, apart from binary gender, be treated as “third gender” for the purpose of safeguarding their rights under Part III of our Constitution and the laws made by the Parliament and the State Legislature. - Transgender persons’ right to decide their self-identified gender is also upheld and the Centre and State Governments are directed to grant legal recognition of their gender identity such as male, female or as third gender - Centre and the State Governments to take steps to treat them as socially and educationally backward classes of citizens and extend all kinds of reservation in cases of admission in educational institutions and for public appointments - Several other directions were issued - Decided in favour of Petitioner.
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2014 (4) TMI 1046
Refusal of registration under section 12AA - Held that:- The reasons for which registration under section 12A was refused appear to be not good reasons. At the time of registration, one has to look into the objects of the trust which the Commissioner of Income-tax has completely omitted to do so. The reasons given by the Commissioner of Income-tax are only apprehensions that the assessee is not carrying out any charitable activities and he was of the view that it is premature to register the trust. - commencement of activity is not a precondition for grant of registration under section 12AA of the Act, once the objects of the trust and genuineness of the activities of the trust are not questioned. In any event, the Commissioner of Income-tax has not examined the objects for which trust has been formed and whether objects are genuine and the activities of the trust are charitable or not. In the circumstances, we are of the view that this matter has to be re-examined by the Commissioner of Income-tax-I, Coimbatore afresh. Therefore, we remand the matter back to the file of the Commissioner of Income-tax - Matter remanded back - Decided in favour of assessee.
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2014 (4) TMI 1045
Disallowance under section 43B - disallowance of depreciation - Held that:- Actual grievance of the appellant is not on merits but on the legal issue regarding limitations on the powers of the CIT(A) on the ground that post 1st June 2001, it is no longer open to the Commissioners (Appeals) to remit the matter to the file of the Assessing Officer, whereas in the instant case, learned CIT(A) has done precisely that. While appellant is right in principle but that aspect of the matter is no longer of any practical significance because neither the assessee has raised any grievances on merits nor such a grievance as is raised before us, even if upheld, will affect the powers of this Tribunal in remitting the matter to the file of the Assessing Officer. Revenue thus derives no practical advantage from raising this issue before us. - as also bearing in mind entirety of the case, we see no reasons to interfere in the matter. In any event, even on merits, the issue regarding merits of impugned additions is covered, in favour of the assessee, by an order of this bench. The technical infirmity, as pointed out in the grounds of appeal, is of no practical significance so far as impugned additions are concerned. Therefore, both the appeals filed by the Revenue are found to have no merit - Decided against Revenue.
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2014 (4) TMI 1044
Exemption under section 54B - Held that:- Since the main issue with regard to exemption under section 54B is remitted back to the file of the Assessing Officer, this Tribunal is of the considered opinion that the fair market value also needs to be reconsidered by the Assessing Officer after giving reasonable opportunity of hearing to the assessee. Accordingly, the orders of the authorities below on this issue are also set aside and the issue of fair market value is also remitted back to the file of the Assessing Officer. The Assessing Officer shall reconsider the issue of the fair market value and decide the same in accordance with law after giving reasonable opportunity of hearing to the assessee. - Matter remanded back - Decided in favour of assessee.
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2014 (4) TMI 1043
Condonation of delay - penalty under section 27(3) and (4) of the TNVAT Act - impugned orders were not served directly on the petitioner - Held that:- Irrespective of the submissions made by the learned counsel on either side, this court is of the view that in the interest of justice, the petitioner may be permitted to file appeal along with applications to condone the delay in filing the appeal. - The petitioner is directed to file appeals against the orders of assessment passed by the first respondent under the Central Sales Tax Act, 1956, by depositing 50 per cent. of the tax amount payable, if the tax amount is not yet paid, within a period of two weeks from the data of receipt of a copy of this order. On such deposit, the second respondent is directed to entertain the appeals along with applications to condone the delay and decide the same on merits and in accordance with law without rejecting the same on the ground of limitation - Decided conditionally in favour of assessee.
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2014 (4) TMI 1042
Deduction u/s 80IB(10) of the Act – Profits from sale of housing projects – Held that:- The decision in CIT v. Radhe Developers [2011 (12) TMI 248 - GUJARAT HIGH COURT] followed - the assessee had taken full responsibilities for execution of the development projects - the assessee had full authority to develop the land as per his discretion - The assessee could engage professional help for designing and architectural work - Assessee would enroll members and collect charges - Profit or loss which may result from execution of the project belonged entirely to the assessee - the assessee had developed the housing project - the Tribunal committed no error in holding that the assessees were entitled to the benefit u/s 80IB(10) of the Act even where the title of the lands had not passed on to the assessees and in some cases, the development permissions may also have been obtained in the name of the original land owners – Decided against Revenue.
Sale of unutilized FSI – Construction done only on the portion of FS available – Held that:- Marginal underutilization of FSI certainly cannot be a ground for rejecting the claim u/s 80IB(10) of the Act - Even if there has been considerable underutilization, if the assessee can point out any special grounds why the FSI could not be fully utilized, the case may stand on a different footing - in cases where the utilization of FSI is way short of the permissible area of construction, looking to the scheme of section 80IB(10) of the Act and the purpose of granting deduction on the income from development of housing projects envisaged, bifurcation of profits arising out of such activity and that arising out of the net sell of FSI must be resorted to - none of the assessees have made any special ground for non-utilization of the FSI- Decided in favour of Revenue.
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2014 (4) TMI 1041
Demand of service tax - Held that:- demands issued in the year 2002 for the period 16.11.97 to 1.6.98 are barred by limitation. Apart from the fact that original adjudicating authority has himself not imposed any penalty on the respondents on the ground of absence of any suppression or mis-statement, there are various decisions of the Tribunal as upheld by the High Court, laying down that in such a scenario, the extended period of limitation cannot be invoked. It may be seen that there were number of cases involving more or less identical period till 1.6.98 when the show cause notices were issued after the retrospective amendment. In all such cases, the Tribunal held that no malafide can be attributed to the assessee and the show cause notices are barred by limitation. One such reference can be made to Honble Gujarat High Court decision in the case of CCE Vadodara vs. Eimco Elecon Ltd. [2010 (7) TMI 477 - GUJARAT HIGH COURT] wherein the appeal filed by the Revenue was rejected on merits, as well as on limitation. The Tribunals decision in the case of CCE Raipur vs. Jaiswal Equipment & Holdings P Ltd. [2007 (6) TMI 31 - CESTAT, NEW DELHI] can also be referred - Decided against Revenue.
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2014 (4) TMI 1040
Demand of service tax - Intellectual property service - Franchise agreement - manufacture and sale of beer using the brand name and technical know-how of another person - Held that:- As per the agreement between the parties, the risk of manufacture and sale lies with the appellant in respect of the Foster Brand beer got manufactured by it from FIPL. It is evident from the contract that FIPL is only responsible for bottling, packing and dispatch as per the specification, terms, formula etc. as laid down by the appellant. Further, FIPL is bound to charge the price from the notified Indenter of the appellant as fixed by the appellant. Only for the risks associated with the manufacturing process fastened on FIPL (CBU), it cannot be said that as FIPL is responsible for proper quality, quantity and timely production, they are providing Franchise Service and/or IPR Service - Decided in favour of assessee.
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2014 (4) TMI 1039
Waiver of pre deposit - Mobile telephone services - Held that:- Prima facie, there is infraction of law laid down. However, it is prima facie clear that the services received by the applicant from other service providers to extend roaming facility to applicant's subscribers is an input service for the applicant. Thus the advocate for the applicant has been able to demonstrate that the facts of his case has not resulted in any revenue loss and he has also explained that this happened only for a brief period. Therefore, at this stage, we consider it proper to grant waiver of pre-deposit of dues for admission of appeal. It is so ordered and there shall be stay on collection of such dues arising from the impugned order during pendency of the appeal - Stay granted.
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2014 (4) TMI 1038
Demand of service tax - construction of Commercial or Industrial complexes and also Residential Complexes. - Held that:- In the matter of free supply materials, there is already a decision of the Tribunal in favor of the assessee [2013 (9) TMI 294 - CESTAT NEW DELHI] and the other disputed issue stands referred to a Larger Bench of the Tribunal. In the circumstances, we consider the deposit already made by the applicant is sufficient for admission of appeal and there shall be stay on collection of such dues till the disposal of the appeal - Stay granted.
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2014 (4) TMI 1037
Waiver of pre deposit - Mobile Telephone Services - Held that:- as on date no other company providing similar services has been made to pre-deposit any money on this issue for hearing their appeal. Therefore, we consider it proper to maintain parity among the various parties involved on the same issue. Hence, we order waiver of the requirement of pre-deposit of dues arising from the impugned orders for admission of the appeals and stay collection of such dues during the pendency of the appeals - Stay granted.
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2014 (4) TMI 1036
Condonation of Delay of 1 year and 128 days – Bar of limitation - "sufficient cause" u/s 5 of Act, 1963 – Held that:- Judgment in Collector, Land Acquisition Vs. Katiji [1987 (2) TMI 61 - SUPREME Court] followed - When substantial justice and technical considerations are taken against each other, cause of substantial justice deserves to be preferred, for, the other side cannot claim to have vested right in injustice being done because of a non-deliberate delay - The Court further said that judiciary is respected not on account of its power to legalise injustice on technical grounds but because it is capable of removing injustice and is expected to do so - The statute providing limitation is founded on public policy - It is enshrined in the maxim Interest reipublicae up sit finis litium (it is for the general welfare that a period be put to litigation) – Lapse on the part of litigant in approaching Court within time is understandable but a total inaction for long period of delay without any explanation whatsoever and that too in absence of showing any sincere attempt on the part of suiter, would add to his negligence, and would be relevant factor going against him.
Relying upon Vedabai @ Vaijayanatabai Baburao Vs. Shantaram Baburao Patil and others [2001 (7) TMI 117 - SUPREME Court] - The Court said that u/s 5 of Act, 1963 it should adopt a pragmatic approach - A distinction must be made between a case where the delay is inordinate and a case where the delay is of a few days - In the former case consideration of prejudice to the other side will be a relevant factor so the case calls for a more cautious approach but in the latter case no such consideration may arise and such a case deserves a liberal approach – Here, if delay has occurred for reasons which does not smack of mala fide, the Court should be reluctant to refuse condonation, will not help the petitioner in any manner since it is found that here is a case which shows a complete careless and reckless long delay on the part of applicant, which has remained virtually unexplained at all - Therefore, this Court do not find any reason to exercise judicial discretion exercising judiciously so as to justify condonation of delay in the present case.
Since it is contended that issue raised are substantially in public importance, this Court has also looked into merits of the matter and finds that first Appellate Court as well as Tribunal both recorded findings of fact in favour of assessee and there is no patent or otherwise illegality therein - No question of law has arisen in this case, particularly when findings of fact recorded by first appellate court as well as Tribunal are also not shown perverse or contrary to material on record - This is not a case wherein substantial questions are involved and would go undecided on account of unsatisfactory delay by revisionist - The application seeking condonation of delay is, therefore, rejected – Decided in favour of Revenue.
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2014 (4) TMI 1035
Validity of Tribunal order – Inclusion of entry tax in taxable turnover – Whether in view of Section 4(2) of Entry Tax Act, 1990, the entry tax paid by the assessee form part of their taxable turnover – Held that:- Going by the model invoice produced before the Assessing Authorities, the total consideration charged by the assessee was inclusive of entry tax – The assessee had excluded the entry tax which was part of the consideration and had charged sales tax - assessment was revised to assess the taxable turnover under Section 16(1)(a) of the Act - The mere fact that entry tax payment would be adjusted against the sales tax liability as per Section 4 of the Entry Tax Act, would not come to the aid of the assessee to contend that sales tax at 12% was to be levied on the price excluding entry tax - Tax Cases stand dismissed – Decided against assessee.
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2014 (4) TMI 1034
Payment of predeposit - Option to pay in installments – Meeting the ends of justice – Held that:- As such the appellant ought to have approached the Tribunal for installments at the earliest and ought not to have waited till 2013 - The question is only w.r.t. the predeposit and appellant shall be given an opportunity to submit the case on merits on payment of interest at the rate of 10% p.a. from 9.9.2010 till actual payment is made, the appellant may be given further six months time to make the payment of ₹ 22,96,969/and on that appeal shall be decided by the appellate authority on merits - If the appellant is granted time upto 31.12.2013 to make the payment of aforesaid amount by granting six months EMI with 10% interest on the aforesaid amount from 9.9.2010 till 31.12.2013, it will meet the ends of justice.
Appeals succeed in part and the impugned order of Tribunal dated 11.3. is modified and common appellant is granted further time to make the payment on or before 31.12.2013 and to be paid in 6 EMIs with condition that the appellant shall make the payment with 10% interest p.a. from 9.9.2010 till 31.12.2013 and the aforesaid amount of interest shall be paid in last installment - Aforesaid payment of interest shall be irrespective of outcome of the decision of the appellate authority on remand and the same is while granting further six month installments - On deposit of aforesaid amount with interest thereon, the appeals preferred by the appellant shall be decided and disposed of by the appellate authority on merits as ordered by the Tribunal in Second Appeal - If the appellant fails to make the payment of aforesaid amount stated above within stipulated time, it will be open for the Officer/ appropriate authority to recover the amount under the order of assessment which shall be without prejudice to any further proceedings for breach of undertaking - All appeals disposed of – Decided partly in favour of assessee.
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2014 (4) TMI 1033
Bar of Limitation – Claim for Deduction - Requirement to abide by time limit u/s 4-D- Turnover as per Section 2(r) present or not – Held That:- Assessee does not dispute the fact that at least in certain cases it had failed to file the Form within 30 days of the receipt of the goods returned, and even in cases where the same had been filed within 30 days, it failed to give such details, which are required under law to be given - Assessee does not make a dispute on this aspect that the claim for unfructified sale could be entertained only subject to the assessee satisfying those conditions and the question of refund arises only when the assessee satisfies the assessing authority that in fact, there had been an unfructified sale - Assessee had not shown any reasons for the belated filing – Assessee had not filed Form A-4 within 30 days time limit prescribed and even thereafter, before the Appellate Authority without prescribed particulars on the belated filing, there is no justification to grant the relief - Thus, in the absence of any material to show that the assessee had given sufficient cause for not making a claim before the Assessing Authority in the manner prescribed under the law.
Relyin upon State of Andhra Pradesh Versus Hyderabad Asbestos Cement Production Ltd. [1994 (4) TMI 302 - SUPREME COURT OF INDIA] an appeal being a continuation of the assessment, the assessee may file Form A-4 before the Appellate Authority and the same would be subject to the assessee showing and satisfying sufficient cause and not otherwise - However, where there lies no dispute on the claim of unfructified sale, the claim must necessarily go by the provision of the Act and the Rules.
As for the Forms filed beyond 30 days, in the absence of any satisfactory explanation, case of assessee is not acceptable - Thus, we accept the plea of the assessee for a remand only in respect of cases where the claim was made within 30 days of the receipt of the goods on unfructified sale with the complete details - Revision filed by the assessee stands dismissed in respect of the turnover for which the Forms were filed beyond 30 days' time frame and without assigning any reason before the Appellate Assistant Commissioner - However, in respect of forms filed within time, the Assessing Officer is directed to consider the claim – Decided partly in favour of assessee.
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2014 (4) TMI 1032
Validity of CESTAT Order - Non consideration of relevant material - Held that:- Since the CESTAT did not go into merits of the case and set aside the order of the Commissioner of Central Excise, Bangalore, without examining the effect of non-supply of the documents or without examining whether the said documents have any effect on merits of the case - Matter remanded back - Decided in favour of Revenue.
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2014 (4) TMI 1031
Denial of CENVAT Credit - Interest under Rule 14 of the Cenvat Credit Rules 2004 read with Section 11AB of the Central Excise Act, 1944 - Held that:- while passing the OIO the adjudicating authority has denied the CENVAT credit to the petitioner on various other grounds for which no show cause notice was issued and no opportunity has been given to the petitioner. It appears that the show cause notice for denying the CENVAT credit was issued only on the ground that the petitioner has availed the credit of service tax on commission for sale of finished goods, which cannot be said to be relating to manufacturing activities but relating to sales activities (i.e. after manufacturing activities). However, while passing the OIO though the adjudicating authority has held that Business Auxilliary Service (BAS) on account of sales commission can be considered as Input Service within the definition of rule 2(I)(ii) of Cenvat Credit Rules, 2004 and the service tax paid on the said service is admissible as credit to the manufacturer, subject to certain conditions, the adjudicating authority has denied the Cenvat credit on altogether other grounds (mentioned in para 12.4 to 12.6 of the OIO) for which admittedly no show cause notice has been issued and no opportunity has been given to the petitioner. Under the circumstances, the OIO dated 31.03.2012 can be said to be in breach of principle of natural justice. Under the circumstances, the impugned OIO deserves to be quashed and set aside and the matter is remanded to the first adjudicating authority to consider the issue afresh in accordance with law and on merits - Decided in favour of assessee.
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2014 (4) TMI 1030
Waiver of pre deposit - Held that:- When the legislation has not made any distinction, we cannot make such distinction by judicial order. Therefore, we do not find any error in the order passed by the appellate authority for insisting the payment of the entire amount of duty as a condition precedent for entertaining the appeal. However, at that stage itself the Tribunal appears to have made up its mind to the effect that the appellant is not entitled to the benefit of this input tax, which was erroneous. The appellant is yet to argue the case on merits. The respondent is also to be heard. It is only thereafter the Tribunal can come to the conclusion one way or the other. Therefore, the observations made on the merits of the appeal should not be taken into consideration as a binding precedent while deciding the appeal on merits. The tribunal shall consider the matter on merits and in accordance with law, ignoring the observations made by it in the impugned order, that would meet the ends of justice - stay denied.
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