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Showing 341 to 360 of 1740 Records
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2024 (9) TMI 1402
Grant of leave - HELD THAT:- There is nothing placed on record by the respondents to show that the process in terms of order dated 8th April, 2024 passed by the Chief Judicial Magistrate Gautam Buddha Nagar, Uttar Pradesh was served upon the appellant. Apart from this, though on 29th April, 2024, interim relief was granted by this Court to the appellant on condition of cooperating for investigation, the counter affidavit and additional counter affidavit filed by the respondent-State show that even a notice was not issued during the last about four months calling upon the appellant to appear for investigation. The presence of the appellant was not required for about four months.
The interim order passed by this Court on 29th April, 2024 is made absolute on the same terms and conditions - Appeal allowed.
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2024 (9) TMI 1401
Violation of principles of natural justice - tax adjudication process under U.P. GST Act, 2017 - HELD THAT:- It is found that no opportunity of personal hearing as was requested by the petitioner in his reply to the show cause notice was given to the petitioner before the impugned order has been passed. Therefore, the writ petition allowed. The impugned order dated 17.08.2022 is hereby set-aside.
Since the petitioner has already given a reply to the show cause notice issued earlier, the Assessing Officer shall fix a date, time and place of hearing and give proper opportunity of personal hearing to the petitioner within a period of two weeks' from the date of certified copy of this order is produced before him.
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2024 (9) TMI 1400
Detention of the goods and vehicle of the petitioner - Section 129 of the Central Goods and Services Tax Act, 2017 read with Section 20 of Integrated Goods and Services Tax Act, 2017 - whether the goods may be released by the authorities under Section 129(1)(a) or 129(1)(b) of the CGST Act read with IGST Act? - HELD THAT:- The present case is squarely covered by the judgment of this Court in H/S HALDER ENTERPRISES VERSUS STATE OF U.P. AND OTHERS [2023 (12) TMI 514 - ALLAHABAD HIGH COURT] where it was held that 'The order passed by the authorities dated October 19, 2023 is quashed and set aside. The authorities are directed to carry out the exercise in terms of Section 129(1)(a) of the CGST Act within a period of three weeks from today'.
On a bare perusal of the record and the judgment cited above, it is found that there are no reason why this Court should take a different view of the matter. Ergo, the goods would have to be released in terms of Section 129(1)(a) of the CGST Act read with IGST Act.
The order passed by the authorities dated September 12, 2024 is quashed and set aside. The respondent authorities are directed to carry out the exercise in terms of Section 129(1)(a) of the CGST Act read with IGST Act within a period of three weeks from today - Petition allowed.
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2024 (9) TMI 1399
Dismissal of Appeal - appeal was considered to have been filed beyond 3 months from the date of communication of the order impugned in the said appeal - petitioner has not provided any acceptable evidence to prove that date of communication of order-in-original - HELD THAT:- The order-in-appeal dated 5th July 2024 is set aside - matter remanded for de novo consideration.
Appellate Authority who will hear this appeal shall give personal hearing to Appellant, notice whereof shall be communicated at least 5 working days in advance. The order to be passed shall be a reasoned order dealing with all submissions of Appellant. If the Appellate Authority is going to rely on any order or judgment of any Court or Tribunal or any other forum, a list thereof shall be made available along with the notice for personal hearing. If the order or a judgment is unreported then a copy thereof shall also be made available along with the notice. This is to enable Appellant to deal with/distinguish the judgment or the order.
The appeal shall be disposed by 30th November 2024.
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2024 (9) TMI 1398
Extension of time limit for passing and order u/s 73 - Absence of recommendation of GST Council - Absence of corresponding state government notification parallel to Central Govt. Notification - Non-fulfilment of condition precedent for issuance of the Notifications in exercise of powers under Section 168A of the Central Act - whether the Notification No.56/2023-CT dated 28.12.2023, is ultra vires the provisions of Section 168A of the Central Act? - HELD THAT:- It is apparent that for the Government to exercise the powers under Section 168A to extend the time limit specified or prescribed or notified, it can be made on the recommendation of the GST Council by way of a notification in respect to acts which could not be completed or complied with due to force majeure. The challenge to the Notification No.56/2023-CT is on account of absence of recommendation by the GST Council and existence of force majeure as defined in the Explanation to Section 168A of the Central Act.
In the case of V.M. Kurian Vs. State of Kerala [2001 (3) TMI 1091 - SUPREME COURT], the Supreme Court was dealing with Rule 5 of Kerala Building Rules and the question which arose was whether without the recommendation of Greater Cochin Development Authority and the Chief Town Planner, the State Government could have granted exemption from the operation of the Kerala Building Rules for construction of an eight storey building. The Supreme Court in the said judgment observed that the word “recommendation” is “a statement expressing commendation or a message of this nature”. However, taking into account that the word “recommendation” was not defined in the Kerala Building Rules, it was observed that the meaning of the word “recommendation” has to be understood in the context of the provisions of the Kerala Building Rules and the object behind the Rules.
In the instant case, it would be seen that both the Central Act as well as the State Act do not define the term “recommendation”. Under such circumstances, it would be necessary to understand the impact of the word “recommendation” in the context of the provisions of the Constitution as well as the Central Act and State Act - It is also pertinent to take note of that the said power conferred on the Parliament and the State Legislature is not subject to Article 279A except to the extent that in respect to the Goods and Service Tax to be levied on petroleum, crude, high speed diesel, motor spirit (commonly known as petrol), natural gas and aviation turbine fuel, the power can be exercised under Article 246A from the date recommended by the GST Council.
It is apparent that the object behind the insertion of the Article 246A and Article 279A and overriding Article 254 is to promote fiscal federalism and cooperative federalism. Under such circumstances, the recommendations to be made by the GST Council if required as per the provisions of the Central Act or the State Act has to be construed to be a sine qua non for exercise of power by the Union or the State Government. In other words, wherever the provisions of the Central Act or the State Act stipulates that an act is required to be done on the recommendation of the GST Council, the act can be done only when there is a recommendation.
This Court is of the opinion that the Notification No.56/20123-CT is ultra vires the Central Act and the same is not legally sustainable in law. Accordingly, the same is set aside and quashed - the impugned Orders-in-Original which have been passed under Section 73(9) both under the Central Act as well as State Act are beyond the time period prescribed under Section 73(10) of both the Central Act or the State Act for which the same are liable to be interfered with as being passed without jurisdiction.
Petition allowed.
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2024 (9) TMI 1397
Rejection of appeal of the petitioner on the ground that the same is filed beyond the period of limitation - HELD THAT:- The impugned order dated 08.12.2023 passed by the appellate authority is set aside and the matter is remanded before the first appellate authority (respondent no.1) with a direction to consider and adjudicate upon the appeal filed by the petitioner on merits without raising any objection on the limitation, after notice and opportunity of hearing to all concerned.
Petition disposed off.
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2024 (9) TMI 1396
Quashing of SCN issued to a petitioner in a tax matter due to the dissolution of a partnership firm - the petitioner submit that he is willing to participate in the proceedings before the department as tax payments with regard to the firm have been made and the petitioner is willing to show the same to the department.
HELD THAT:- The impugned order dated April 28, 2024 issued by the respondent no.2 [Annexure No.9] as well notices dated December 16, 2023/December 19, 2023 and April 23, 2024 [Annexure Nos.5 & 6] are quashed and set aside with liberty granted to the respondent authorities to proceed against the petitioner and other legal heirs of the partner in accordance with law.
Petition disposed off.
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2024 (9) TMI 1395
Detention of the goods and vehicle of the petitioner - Section 129 of the Central Goods and Services Tax Act, 2017 read with Section 20 of Integrated Goods and Services Tax Act, 2017 - whether the goods may be released by the authorities under Section 129(1)(a) or 129(1)(b) of the CGST Act read with IGST Act? - HELD THAT:- The present case is squarely covered by the judgment of this Court in H/S HALDER ENTERPRISES VERSUS STATE OF U.P. AND OTHERS [2023 (12) TMI 514 - ALLAHABAD HIGH COURT] where it was held that 'The order passed by the authorities dated October 19, 2023 is quashed and set aside. The authorities are directed to carry out the exercise in terms of Section 129(1)(a) of the CGST Act within a period of three weeks from today'.
On a bare perusal of the record and the judgment cited above, it is found that the facts and issue in the present writ petition are quite similar to one in M/s Halder Enterprises. In light of the same, there are no reason why this Court should take a different view of the matter. Ergo, the goods would have to be released in terms of Section 129(1) (a) of the CGST Act read with IGST Act.
The order passed by the authorities dated July 29, 2024 is quashed and set aside. The authorities are directed to carry out the exercise in terms of Section 129(1) (a) of the CGST Act read with IGST Act within a period of three weeks from today - Petition allowed.
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2024 (9) TMI 1394
Challenge to orders related to audit and intimation liability issued against the petitioner - Section 65 of the CGST Act, 2017 - HELD THAT:- In the instant case, it is a matter of record and an undisputed fact that the claim of the respondents are in relation to the petitioner-Company for the financial years 2018-19 and 2019-20 and the impugned order dated 29.04.2024 in relation to the financial year 2018-19 and the impugned proceedings in relation to financial year 2019-20 are clearly without jurisdiction or authority of law in the light of the undisputed fact that the Resolution Plan has already been approved by the NCLT and the judgments referred to supra. Under these circumstances, the impugned order and the proceedings deserve to be quashed.
Petition allowed.
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2024 (9) TMI 1393
Challenge to Order of Seizure - challenge to provisional attachment of bank account - pre-show cause intimation and SCN - HELD THAT:- Upon issuance of the pre-show cause notice intimation and the show cause notice which was based upon the records, papers, documents etc., seized by the respondents, the same would not be required any longer and reliance placed on the said documents would not subsist any longer and the respondents are to be directed to return back the said documents, especially when the petitioner is into real estate business and the documents are required for the purpose of its business. Under these circumstances, though the order of seizure dated 09.01.2024 does not require to be interfered with in the light of the issuance of the pre-show cause notice intimation and the show cause notice issued by the respondents, suffice it to state that direction are to be issued to the respondents to return back all the documents seized by them vide Annexure-E dated 09.01.2024.
Insofar as the impugned provisional bank attachment orders at Annexures-L1, L2 and L3 dated 28.05.2024 are concerned, in the light of the specific contention of the petitioner that out of the total alleged liability of Rs. 5,10,47,405/-, the petitioner has only discharged Rs. 3,60,00,000/- in the States of Karnataka and Telangana coupled with the interim order passed by this Court on 21.08.2024 staying the attachment of bank accounts, without prejudice to the rights of the respondents to proceed further after taking appropriate decision in pursuance of the show cause notice, it is deemed just and appropriate to set aside the provisional bank attachment order reserving liberty in favour of the respondents to proceed in this regard.
The petition is hereby partly allowed.
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2024 (9) TMI 1392
Invocation of revisional jurisdiction conferred u/s 108 of KGST Act - HELD THAT:- Though several contentions have been urged by both sides in respect of their respective claims, having regard to the undisputed fact that the petitioner was not notified nor provided any opportunity by respondent No. 3 before passing the impugned order purporting to invoke Section 108 of KGST Act, it is deemed just and appropriate to set aside the impugned order reserving liberty in favour of the respondent to take appropriate steps in accordance with law after duly notifying the petitioner and hearing him in accordance with law.
Impugned order at Annexure-A dated 21.05.2024 passed by respondent No. 3 is hereby quashed - petition allowed.
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2024 (9) TMI 1391
Initiation of proceedings u/s 129 of the CGST / SGST Acts - applicability of provisions of Rule 55 of the CGST Rules - HELD THAT:- It is not disputed that the goods were covered by Exts.P4, P5 and P6 delivery notes and Ext.P7 E-Way bill. Though, on the top of Ext.P7 E-Way bill only one delivery note is mentioned, the same is stated to be on account of difficulty in entering the details of 3 delivery notes on one E-Way bill. However, numbers of other two delivery notes are seen included in the column for 'transportation details' in the E-Way bill. That apart, a perusal of Exts.P4, P5, P6 and P7 will indicate that the value of the goods had been correctly mentioned and the entire amount of tax to be paid had also been mentioned. There is no finding in Ext.P17 that would indicate that there is any attempt to evade any tax.
It is clear that Rule 55 of the CGST Rules, 2017 applies only to the four circumstances mentioned in Rule 55 (a) to (d) and supply of Acetylene Gas is not covered by Rule 55 (a). Therefore, the goods should have been covered by a tax invoice.
The competent among the respondents are directed to consider the case as one covered by the provisions of Section 122 of the CGST /SGST Acts and impose appropriate penalty in terms of the provisions contained in that Section. Any amount recovered from the petitioner on account of ExtP17 order shall either be refunded or shall be adjusted against any future tax liability, by crediting the electronic cash register of the petitioner - petition disposed off.
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2024 (9) TMI 1390
Challenge to action on the part of the Central Board of Indirect Taxes and Customs in issuance of a notification bearing No. 56/2023 dated 28.12.2023 - validity of notification extending the time limit for passing orders under Section 73(9) of the CGST Act, 2017 - HELD THAT:- It prima facie appears that the notification bearing No. 56/2023 is not in consonance with the provisions of 168 (A) of the Central GST Act, 2017. If the said notification cannot stand the scrutiny of law, all consequential actions so taken on the basis of such notification would also fail.
This Court duly takes note of the submission of Mr. S.C Keyal, the learned Standing counsel that the Petitioner would be entitled to the reliefs as proposed in the Financial Bill 2024. In addition to that, this Court also finds that an examination would be required as regards the applicability of the force majeure in respect to the notification bearing No. 56/2023 taking into account 7/7 the contents of the Minutes of the 49th Meeting of the GST Council. However for the purpose of deciding the same, this Court is of the opinion that an opportunity has to be granted to the Respondent Authorities to place on record their stand as well as bringing on record the materials on which they claim the applicability of the force majeure.
This Court is of the opinion, that the Petitioner herein is entitled to an interim protection pending the notice. Till the next date, no coercive action shall be taken on the basis of impugned assessment order dated 30.04.2024 - The Respondents are directed to file their affidavits on or before 13.09.2024.
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2024 (9) TMI 1389
Challenge to bank attachment notice - impugned order passed without even granting an opportunity of personal hearing to the petitioner, nor calling for any reply from the petitioner - violation of principles of natural justice - HELD THAT:- Initially, petitioner herein was registered under the provisions of the Service Tax Act, during which period, the petitioner has appointed an Auditor as his Authorized representative in respect of Service matters; however, subsequent to the introduction of GST regime, though the petitioner got registered under the provisions of the GST Act and also shifted their place of business from AGT Business Park, Avinashi Road, Coimbatore to PMR Layout, Second Street, Poongothai Nagar, Civil Aerodrome post Citra, Coimbatore, the petitioner failed to give authorisation as regards GST matters, during which point of time, the show cause notice was served on the petitioner’s Auditor and for the reasons best known to the Auditor, the same was failed to be brought to the notice of the petitioner. Therefore, the petitioner was not in a position either to give reply to the show cause notice nor appear before the first respondent for the personal hearing.
It was only owing to the fault on the part respondent-Department, the petitioner became unaware of the entire proceedings and was not in a position to respond to such notices, this Court is of the view that the petitioner is entitled to the relief sought for in both the Writ Petitions.
The Order-in-Original is set aside and the matter is remanded back to the first respondent for fresh consideration, however, the same is subject to the payment of 7.5% of the disputed tax by the petitioner within a period of four weeks from the date of receipt of a certified copy of this order - Petition allowed by way of remand.
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2024 (9) TMI 1388
Levy of Service Tax on royalty - challenge to SCN - HELD THAT:- The SCN has already been issued on 20.10.2021 and the petitioner was called upon for personal hearing in pursuance of the said show cause notice, the remedy lies on the petitioner to pursue his case before the authorities in the show cause notice issued on 20.10.2021 and to raise all his grievances there.
In view of the judgment of Hon’ble Supreme Court passed in Mineral Area Development Authority Case [2024 (7) TMI 1390 - SUPREME COURT (LB)] the present petition is disposed of, however, since the notice dated 23.02.2024 has already lost its efficacy as the date mentioned in the notice is already expired, therefore, it would be appropriate to direct the petitioner to appear before the authority concerned on 28/08/2024 and then the authority concerned after giving the proper opportunity of hearing to the petitioner, decide the case in accordance with law.
Petition disposed off.
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2024 (9) TMI 1387
Applicant (THDCIL) is a Government Entity or not? - Legal Services provided by the advocates including Senior Advocate or firm of Advocate is exempt from GST for THDCIL - reverse charge mechanism - HELD THAT:- In order to qualify as a “Government Entity”, such ENTITY must be either “set up by an Act of Parliament or State Legislature;” or “established by any Government, with 90per cent, or more participation by way of equity or control, to carry out a function entrusted by the Central Government, State Government, Union Territory or a local authority”.
The applicant is claiming to be a “Government Entity”, by interpreting the definition as Government Entity means an authority or a board or any other body including a society, trust, corporation, established by any Government, with 90 per cent, or more participation by way of equity or control, to carry out a function entrusted by the Central Government, State Government, Union Territory or a local authority - as on the date of filing of the application dated 01.05.2024 for the present proceedings, the Equity in the applicant company i.e. THDC India Limited is shared between NTPC Limited and Government of UP in a ratio of 74.496 % and 25.504 %, which is less than the stipulated 90% of equity and hence does not fulfill the condition of “with 90 per cent, or more participation by way of equity or control,”.
There is no doubt that at the time of registering the Company, as a Public Limited Company, under the Companies Act, 1956, in July’ 1988, the Government had 100 % equity or control (Govt, of India and Govt, of Uttar Pradesh in the ratio of 75:25), but as admittedly accepted by the applicant in their application and during the course of personal hearing on 07.06.2024, the equity or control of the Government became less that 90 %, as Government of UP held only 25.504 % of the total equity i.e. paid up capital - the status of the applicant i.e. the Company with respect to equity or control of the Government did not remained same and got reduced to 25.504 %, which is less than the stipulated 90 % or more.
At present the equity or control of the Government is less than the stipulated 90% and hence cannot be categorized and considered as “Governmental Entity” in terms of Notification No 11/2017-Central Tax (Rate), dated 28 June’2017, as amended by the Notification No. 31/2017-Central Tax (Rate), dated 13 October’ 2017. And hence the provisions of Entry No. 45 of the Notification No. 12/2017-Central Tax (Rate), dated 28 June’2017, shall not be applicable in the case of the applicant.
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2024 (9) TMI 1386
Validity of appeal filed u/s 260A - Bogus LTCG - whether any substantial question of law has arisen for consideration? - reexamining appellant's additional documents obtained through the Right to Information Act - as argued Tribunal has failed to consider the report of the Securitisation and Exchange Board of India in its proper perspective - as decided by HC [2024 (6) TMI 1068 - CALCUTTA HIGH COURT] CIT(A) has examined the factual aspects with regard to the trading of shares in a company called, Sulabh Engineers & Services Ltd. After examining the facts, the CIT(A) brought out the modus operandi and has recorded finding as to how the claim for long-term capital gain is a bogus claim. The conclusion arrived at by the Tribunal has also been supported by various decisions of the courts - no grounds to interfere with the order passed by the Tribunal
HELD THAT:- The Special Leave Petition is dismissed.
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2024 (9) TMI 1385
Substantial question of law - retrospectivity of the amendment made to Section 23(b) of the Finance Act, 2017, the ground of deduction of overdue interest qua the ideal guidelines has not been considered by the Tribunal in its true perspective - As decided by HC [2023 (6) TMI 742 - MADHYA PRADESH HIGH COURT] retrospectivity was not of Section 43-D of the Finance Act, 2017, it seems from the record that the Tribunal has applied its mind to the ground raised by the appellants while the other ground of deduction of overdue interest qua RBI guidelines is also discussed.
HELD THAT:- We are not inclined to interfere with the impugned judgment and order passed by the High Court which has only confirmed the order of remand passed by the Income Tax Appellate Tribunal (ITAT) [2022 (5) TMI 224 - ITAT JABALPUR].
We are informed by respondent that the petitioner has availed Vivad se Vishwas - Settlement Scheme for the Assessment Year 2013-2014.
If the petitioner seeks to avail the same remedy for the AY 2009-2010 and 2014-2015, we leave it open to the petitioner to make necessary applications. Upon such applications being filed, the procedure contemplated under the law shall be followed and applications be disposed of expeditiously. SLP disposed of.
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2024 (9) TMI 1384
Allowable business/revenue expenditure - admissibility of compensation paid as expenditure u/s 37 (1) - as submitted respondent has not incurred the said expenditure for the purpose of business - ITAT justification in allowing the claim of assessee u/s 37 (1) when the assessee has not acquired the said property as fixed asset nor it has started yielding revenue?” - Revenue assailing the order of the Tribunal contends that the assessee is not the owner of any of the properties, which were the subject matter of the agreement with the purchaser and the agreement entered into with the purchaser was not entered into by the assessee. That the chronology indicates that the transaction is a sham transaction and damages cannot be claimed u/s 37 (1)
HELD THAT:- The properties/rights which were the subject matter of the agreement dated 2.4.2002 did not belong to the firm during the said period i.e., AY 2005-06. Further, the assessee admittedly did not contract with MIPL to provide the built up area in the four properties mentioned in the agreement dated 2.4.2002 nor were any of the four properties mentioned in the said agreement belonged to the assessee nor that the assessee had any manner of right, title or interest in the said properties. The contention of the assessee that the properties belonged to the assessee by virtue of Section 14 of the Act of 1932 is ex facie untenable and liable to be rejected having regard to the fact that there is no material placed on record to demonstrate that the said properties were brought into or were part of the stock of the firm. Hence, the properties cannot by any stretch of imagination be held to be the properties of the assessee firm.
The reasoning of the Tribunal that the advance of Rs. 22.00 crores having been shown in the books of accounts of the assessee and earlier transactions made by Sri Dayanand Pai having been shown as transactions made by the assessee, will also not aid the case of the assessee since the context of the said transaction has not been looked into. In view of the admitted position that the assessee was not the owner of the properties as also that the assessee did not have any manner of right, title or interest in the said properties, which were the subject matter of the agreements dated 2.4.2002 or 10.3.2004, the question of permitting the assessee to claim a deduction u/s 37 (1) does not arise.
Reasoning of the Tribunal that the properties which were the subject matter of the agreement are identified and there was no doubt or ambiguity of the properties to be developed and identified by the assessee for development through other developers and that registration was not a prerequisite condition for acquiring interest, right or title in the constructed area of the properties being developed, is erroneous having regard to the admitted position that the assessee was not a signatory to the agreement dated 2.4.2002 or that the assessee had any manner of right, title or interest in the properties which were the subject matter of the said agreement.
It is the vehement contention on behalf of the assessee that crystallization having been done and the liability having been provided for, the assessee was entitled to claim expenditure during AY 2005-06. The said contention is untenable and liable to be rejected since there is no factual basis for the same, inasmuch as there is no material placed before the authorities to indicate that the liability was crystallized or provided for during AY 2005-06.
Tribunal erred in allowing the appeal of the assessee and setting aside the well considered, concurrent findings of fact recorded by the AO and the Commissioner. The reasoning adopted by the Tribunal is clearly erroneous and contrary to law as noticed above. Decided against assessee.
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2024 (9) TMI 1383
Assessment u/s 153C - disallowance of deduction claimed u/s 10B - HELD THAT:- It is forthcoming that the Tribunal while adjudicating regarding the disallowance of deduction claimed u/s 10B has noticed that the said aspect is covered by a coordinate Bench judgment of this Court in the case of Tata Elxsi Ltd. [2015 (10) TMI 634 - KARNATAKA HIGH COURT] Having regard to the fact that the Tribunal has decided the matter in accordance with a judgment of this Court, the Revenue has not demonstrated as to how the same is erroneous. The substantial question of law No.1 is answered against the Revenue and in favour of the assessee.
AO has not followed the procedure as envisaged u/s 153C - It is relevant to note that Chapter VI of the IT Act contemplates the procedure for assessment, wherein various stipulations are provided in terms of Sections 136 to 153 of the IT Act. Section 153A, 153B and 153C have been inserted by the Finance Act, 2003 w.e.f., 1.6.2003, which specifically contemplates assessments in cases of search or requisition. Section 153A of the IT Act contains various stipulations with regard to the person searched and Section 153C of the IT Act contains various stipulations with regard to such other person, other than the person searched.
A coordinate Bench of this Court in the case of Dinakar Suvarna [2022 (7) TMI 800 - KARNATAKA HIGH COURT] while considering an appeal of the assessee, in a fact situation wherein an assessment was re-opened u/s 147 of the IT Act based on a search conducted and the procedure u/s 153 of the IT Act was not followed was under consideration.
In view of the settled position of law as noticed above, once material pursuant to a search is relied upon, the AO is required to follow the procedure as contemplated under Section 153A, 153B and 153C and it is impermissible for the AO to continue the regular assessment. Decided in favour of the assessee and against the Revenue.
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