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Showing 381 to 400 of 1967 Records
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2014 (1) TMI 1589
Whether sale consideration of a going concern be taxed as capital gains - Slump sale - Held that:- Relying upon the decision in PNB Finance Ltd. V/s. Commissioner of Income-Tax [2008 (11) TMI 7 - SUPREME COURT] - Section 45 charges the profits or gains arising from the transfer of a capital asset to income-tax - The charging section and the computation provisions together constitute an integrated Code and when in a case the computation provisions cannot apply, such a case would not fall within Section 45 - The said sale has taken place prior to the amendment introducing section 50B the concept of slump sale - Merely because the assessee has given split up figures and received the consideration from the purchaser, it would not take the goods out of slump sale - Decided against Revenue.
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2014 (1) TMI 1588
Issues Involved:
1. Disallowance of the claim of loss regarding unrealized sale proceeds under Section 10A of the Income Tax Act, 1961.
2. Treatment of unrealized sales written back as business loss.
3. Calculation of total turnover and export turnover for the purpose of Section 10A deduction.
4. Relevance of the High Court order approving the resolution for adjusting the Securities Premium Account.
Detailed Analysis:
1. Disallowance of the Claim of Loss Regarding Unrealized Sale Proceeds:
The primary legal question was whether the Income Tax Appellate Tribunal (ITAT) was correct in upholding the disallowance of the assessee's claim of loss of Rs.24,32,35,200/- related to unrealized sale proceeds for the assessment year 2001-02. The assessee, a public limited company engaged in software development, hardware sales, and education, claimed a deduction under Section 10A of the Income Tax Act, 1961. The Assessing Officer (AO) noted that out of the total turnover of Rs.205,14,65,831/-, only Rs.70,10,93,076/- had been brought into India by 31.03.2002, with the balance of Rs.135,03,72,755/- still pending. The AO restricted the eligible claim under Section 10A proportionately to Rs.30,86,49,234/-.
2. Treatment of Unrealized Sales Written Back as Business Loss:
The assessee argued that the unremitted sale proceeds, including unrealized sales written back, should be credited as a deduction from taxable income. This was based on a special resolution passed by the shareholders and approved by the High Court, allowing adjustments towards goodwill and erosion in the value of investments. However, the Commissioner of Income Tax (Appeals) and the ITAT rejected this claim, stating that the liability had not crystallized during the year under consideration, and thus, the claim for deduction on unrealized sales did not arise.
3. Calculation of Total Turnover and Export Turnover for Section 10A Deduction:
The assessee contended that the computation by the AO was flawed, as the unrealized amount should be excluded from both the export turnover and the total turnover. The counsel for the assessee argued for a liberal interpretation of the deduction provision concerning STP units. However, the Revenue countered that the assessee did not initially raise this issue before the Commissioner of Income Tax (Appeals) and that the claim was based on a resolution with no relevance to the assessment under consideration. The Revenue further argued that accepting the assessee's contention would result in a distorted figure, contrary to the intent of Section 10A, which aims to augment foreign exchange.
4. Relevance of the High Court Order Approving the Resolution for Adjusting the Securities Premium Account:
The High Court had approved a resolution for adjusting the Securities Premium Account to set off goodwill and erosion in the value of investments. The assessee claimed that this should allow for a deduction of unrealized sales. However, the court noted that as of the date of filing the return and the assessment order, no such claim was made. The court agreed with the Revenue that the resolution had no relevance to the assessment year under consideration, and the claim for business loss was not substantiated.
Conclusion:
The court dismissed the appeal, confirming the ITAT's order. It held that the assessee's claim for deduction on unrealized sales was not justified, as the liability had not crystallized during the assessment year. The court also rejected the argument for parity between export turnover and total turnover, stating that it would result in a distorted figure contrary to the purpose of Section 10A. The High Court's order on the resolution did not advance the assessee's case, and the so-called loss had not crystallized as a business loss during the year under consideration. Thus, the Tax Case (Appeal) was dismissed, and the ITAT's order was confirmed.
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2014 (1) TMI 1587
Whether deduction u/s 80HHC be allowed without reducing therefrom deduction u/s 80IB - Held that:- Section 80HHC of the Act is not a self contained provision - The deduction cannot be allowed ignoring the restrictive clause contained in Section 80-IA(9)- The restrictive clause in Section 80IA makes it abundantly clear that wherever deduction under any other section of Chapter VI-A(C) is claimed, the computation will be subject to the restrictions laid down in Section 80-IA (9) - When provisions of Section 80IB(13) are read in conjunction with Section 80IA(9) of the Act, it becomes clear that deduction under Section 80HHC of the Act is to be computed on the eligible business profits only after reducing therefrom the portion of profit on which deduction has already been availed by the assessee under section 80IB - Decided against assessee.
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2014 (1) TMI 1586
Estimation of expenditure for disallowance u/s 14A - Held that:- The assessee has received the dividend income direct credit in bank account through NEFT, RTGS and also DEMAT Accounts - No human agency is involved in collecting these dividends and interest for which the assessee has to incur any expenditure - These aspects has not been taken note of and the notional expenditure is calculated pre modernization - When the assessee has not incurred any expenditure for realizing this income, the question of holding that 2% of the gross total income is an expenditure is unsustainable - Decided in favour of assessee.
Depreciation on the loss incurred units of CANSTAR or revenue expenditure - Held that:- The object of purchasing the units is to gain public confidence and to mitigate the hardship that is caused to the public - The assessee has invested Rs.999.16 crores for purchase of units and only Rs.500.11 crores was realized on its redemption after maturity, thus, incurring a loss of Rs.499.05 crores - It is in the nature of an expenditure and assessee is entitled to the benefit of Section 37(1) of the Act - The claim of the assessee for depreciation on the basis of diminution of value of the capital asset or even loss sustained in the business would not be appropriate - The assessee would be entitled to the claim as expenditure incurred in the business because the entire amount was invested as commercial expediency with the intention of preserving their goodwill in the business - Decided in favour of assessee.
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2014 (1) TMI 1585
Exemption u/s 54EC and 54F - Held that:- Relying upon the decision in Smt. Saroj Aggarwal v. Commissioner of Income-tax [1985 (9) TMI 6 - SUPREME Court] - It is not necessary that after payment of cost of acquisition, a title deed is to be executed in favour of the assessee - Even in the absence of a title deed, the assessee holds that property - It is the point of time at which he holds the property, which is to be taken into consideration in determining the period between the date of acquisition and date of transfer of such capital gain in order to decide whether it is a short-term capital gain or a long-term capital gain.
Merely because the original site which was allotted was cancelled, yet another site was allotted and the said site was also cancelled and thereafter the present site was allotted, in law - would make no difference - The consideration paid on 21.9.1988 is treated as the consideration for the sale dated 27.2.2008 - The assessee has invested the amount of capital gains as per the law - The assessee has rightly claimed the benefit of exemption under Section 54EC and 54F of the Act - Decided against Revenue.
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2014 (1) TMI 1584
Rectification of mistake - Held that:- The Tribunal has given its finding that the machinery in question was never used by the assessee company - It was used only by the sister concern of the assessee company and the assessee was not entitled to claim depreciation on the said machinery - It can be inferred that the Tribunal has not only considered the submissions of the assessee but has given a categorical finding on all of the issues which were raised before the Tribunal by the ld. counsel for the assessee - Neither any new fact nor any law has been brought by the ld. counsel for the assessee which may be said to be escaped the attention of the Tribunal - The other contentions raised by the assessee through this application have already been duly considered and adjudicated in the impugned order - There is no mistake apparent on the record in the said order which may require any rectification - Decided against assessee.
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2014 (1) TMI 1583
Whether the shares transferred were long term capital asset or not - Held that:- The assessee has filed share transfer form and share certificate to proof that the shares were purchased on 25.10.2005 - If the Assessing Officer had any doubts on these documents, he could have carried out further investigation and gathered evidence to disprove the claim of the assessee - He instead accepted the assessee's claim - The bank entries for receipt of consideration shows that the AO was wrong in doubting the transaction - The Assessing Officer could have summoned the purchasers or taken confirmations from them, in case he disbelieved the transfers - The order of CIT(A) upheld.
Whether the assessee was owner of a residential house at Gadaipur - Held that:- The property was purchased by the appellant in financial year 1995-96 for Rs.60,000/- and the same was shown as agricultural land in the balance sheet as on 31.3.96 - There is no improvement on this property since it is being shown at the same value till financial year ending on 31.3.2007 - The sale deed shows that the property was a piece of agricultural land - The AO didnot considered the facts correctly - The assessee is not a fractional owner of the property at Gadaipur, and hence eligible for deduction u/s 54 of the Act - Decided against Revenue.
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2014 (1) TMI 1582
Penalty u/s 271B - Tax Audit - The assessee failed to furnish bonafide reasons for not getting the books of accounts audited either before the AO or the FAA - Held that:- The assessee's total turnover of the business in transacting shares was higher than the prescribed limit u/s 44AB - It does not differentiate between commodities sold under the head speculative business or normal business - The provision of section 271B of the Act is an enabling provision empowering the AO to direct payment of penalty for non-compliance with the provisions of section 44AB. Section 271B has to be read with provisions of section 44AB of the Act - Decided against assessee.
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2014 (1) TMI 1581
Disallowance of expenses of Net Present Value as compensation paid - compensation paid by the assessee to Forest Department for utilization of forest land for non-forest purposes. - Held that:- Decision in ACIT v. Rungta Sons (P) Ltd. [2014 (1) TMI 1515 - ITAT KOLKATA] followed - The said payment is not a voluntary one and it is a payment on the basis of the direction given by the Government of India - When a payment is made as per specific direction of Government, it cannot but be in the business interest of the assessee-company to abide by such directions of the Government of India - This payment is a statutory requirement and the expenditure has been considered wholly and exclusively for the purpose of business and has got a direct connection with the business activity of the Company - The expenditure resulting in a capital asset in the hands of a third party, is to be taken as revenue expenditure because no asset arises to the trader by reason of such expenditure - Where law imposes on the assessee, an obligation to incur expenses for being permitted to pursue its trading activity, the expenditure would be an outgoing from the profits of the trade.
The said expenditure paid by the assessee as NPV to enable the assessee to carry on its mining business is revenue in nature, which is allowable as business expenditure under section 37(1) of the Act - Decided against Revenue.
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2014 (1) TMI 1580
Estimation of profits u/s 44BB - Mobilization fee for work carried outside India - Held that:- Relying upon the decision in Sedco Forex Inc. v. CIT [2007 (9) TMI 196 - UTTARAKHAND HIGH COURT] - Mobilization charges paid to assessee by ONGC had no nexus with the actual amount incurred by assessee for transportation of drilling units of rigs to India – Mobilization charges weren’t reimbursement of expenditure – In view of fictional taxing provision u/s 44BB, AO is justified in adding the amount received by assessee towards mobilization charges for the purpose of imposing income tax - Decided against assessee.
Reimbursement of communication charges and repair of equipments - Held that:- Relying upon the decision in CIT v. Halliburton Offshore Service Inc. [2007 (9) TMI 230 - UTTARAKHAND HIGH COURT] - As per section 44BB - All the amounts either paid or payable (whether in India or outside India) or received or deemed to be received (whether in India or outside India) are mutually inclusive - This amount is the basis of determination of deemed profit and gains of the assessee at the rate of 10% - Section 44BB provides by a legal fiction to be the profits and gains of the non-resident assessee engaged in the business of exploration at the rate of 10% of the aggregate amount specified in sub section (2) - The Assessing Officer added the said amount which was received by the non resident company rendering services as per provisions of sec. 44BB to the ONGC - Decided against assessee.
Reimbursement of service tax - Held that:- Relying upon the decision in M/s Sedco Forex International Drilling Inc C/o Nangia & Company Versus Assistant Director of Income Tax, International Taxation [2014 (1) TMI 1322 - ITAT DELHI] - service tax being a statutory liability cannot form part of gross receipts for the purpose of deemed profit u/s 44BB - Decided in favour of assessee.
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2014 (1) TMI 1579
Disallowance u/s 14A - Held that:- The assessee had sufficient interest free funds which it had invested in mutual funds and moreover the assessee instead of incurring expenditure in the form of interest has earned income - Ld CIT(A) has rightly deleted the interest component from the disallowance of Rule 8D - Decided against Revenue.
Whether adjustment of disallowance u/s 14A be deleted while computing book profits u/s 14A - Held that:-The provisions of clause (g) to section 115JB refers to the amount of expenditure incurred for earning exempt income which has to be added back to the profit as per P&L A/c for the purpose of calculation of book profits u/s 115JB - The assessee has not incurred any expenditure in earning exempt income - Disallowance u/s 14A has been deleted by the CIT(A) - Decided against Revenue.
Whether income derived from operations & maintenance of SEZ be deleted from book profits when the same has not been claimed by the assessee - Held that:- As per clause (6) of section 115JB - The provision of this section shall not apply to the income accrued or arising on or after the Ist day of April, 2005 from any business carried on or services rendered by an entrepreneur or a developer in a unit or SEZ - The assessee was eligible for exclusion of income from SEZ business for the purpose of section 115JB - The claim of assessee with respect to SEZ income has not been examined by the Assessing Officer or by ld CIT(A) - The issue has been restored for fresh adjudication.
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2014 (1) TMI 1578
Stay application - Waiver of pre deposit - Stay on imposition of redemption fine - Partial assessment duty paid - Held that:- The stay on redemption fine would normally follow from a stay of the order being challenged before the Tribunal. The jurisdiction of the Tribunal to stay the order being appealed against before it is not under Section 129E of the Act but is in the exercise of its inherent power as an Appellate Authority. This power is to be exercised in exceptional circumstances. In this case, nothing has been brought to our notice to show circumstances which would warrant the Tribunal exercising its inherent power to stay the order dated 30 November 2011 of the Commissioner of Customs or the redemption fine imposed therein - appeal itself would be listed for final hearing in the near future, we are of the view that the interests of justice would require that the respondent-revenue be restrained from adopting any coercive proceedings for recovery of redemption fine of Rs.78 lakhs till the final disposal of the appeal before the Tribunal - Decided in favour of assessee.
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2014 (1) TMI 1577
Request for early hearing - Lower appellate authority has directed the appellant M/s Ketan Pharma to approach the learned adjudicating authority, who shall pass a speaking order as per Section 17(5) of the Customs Act, 1962 - However, in spite of the said direction, the learned adjudicating authority has not passed the speaking order - Held that:- there is no fault in lower appellate authority directing the adjudicating authority to pass a speaking order with regard to denial of benefit of exemption claimed by the appellant in Bill of Entry. If the adjudicating authority has not followed this direction, the remedy lies in taking up the matter with the jurisdictional Executive Commissioner. This Tribunal being an appellate authority does not have any authority to control the functioning of the Customs Officer in a particular Commissionerate - Decided against assessee.
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2014 (1) TMI 1576
Maintanability of appeal - Powers conferred under Regulation 21 under CHALR 2004 - Held that:- appeal before this Tribunal lies against the decision passed by the Commissioner (General) under Regulation 20 or Regulation 22(7) of CHALR, 2004. Therefore, we hold that this appeal does not lie before us. Accordingly, we dismiss this appeal as not maintainable, with liberty to appellant to take up alternative remedy before appropriate forum - Decided against assessee.
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2014 (1) TMI 1575
Confiscation of goods - Import of Vanaspati ghee - Imported Goods not as Prevention of Food Adulteration Act (PFA) Rules - Penalty u/s 114A - Held that:- Commissioner has allowed re-export without any redemption fine. Inasmuch as the Revenue has not appealed against the said part of the impugned order, the re-export without any fine is confirmed. It already stands observed by the Tribunal that there was no mala fide on the part of the importer and it was only a question of samples having failed as regards PFA standards - Following decision of assessee's own previous case [2011 (8) TMI 718 - CESTAT, DELHI] - Decided in favour of assessee.
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2014 (1) TMI 1574
Drug Import - Confiscation of goods - Whether the imported goods, which bears a mark that the goods are “feed grade and not for medicinal/human use” being a drug can be imported without obtaining NOC from the Drugs Controller or not - Held that:- appellants are entitled for the benefit of exemption under Rule 43 of the Drugs and Cosmetics Rules, 1945 subject to the undertaking that the end use of the imported goods shall not for medicinal/human use and therefore, the goods are not liable for confiscation, accordingly, the impugned order is set aside. Appeal is allowed with consequential relief. The adjudicating authority is directed to release the impugned goods within seven days on receipt of this order on production of undertaking with regard to the end use - Decided in favour of assessee.
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2014 (1) TMI 1573
Tenancy of property - Petitioner Company did not vacate tenanted premises even after amalgamation - Petitioner paid rents to the landlords whereas landlords would contend, although rent was paid by Petitoner, they did not recognize them as tenant because landlords continued to issue rent receipts in the name of Standard Pharmaceuticals Limited, the original tenant - Held that:- Standard Pharmaceuticals Limited stood dissolved long ago that was not in the knowledge of the landlord hence, they continued to issue rent receipts in the name of the original tenant. Ambalal, although paid rent, did not inform about the change. They also did not protest and accepted rent receipts issued in favour of Standard Pharmaceuticals Limited a non-existent Company. In an Order of Amalgamation, the shareholders at large as well as the transferee company in their wisdom would decide to merge one with the other, as a consequence of merger the assets and liabilities of the transferor would automatically vest unto the transferee and the transferor would become a non-existent entity and in course of time would get dissolved. Same is the situation here; once the company stood dissolved the tenancy would automatically perish. The order of amalgamation, although an order in rem, is rendered at the instance of the shareholders of both the companies including the transferor tenant hence, the Order of Amalgamation would not protect the tenancy.
Shareholders of the transferor Company decided to merge with Ambalal. It was their wisdom that would have no bearing on the landlord who was not taken in confidence. Be it assignment, be it transfer, be it sub-letting, the tenancy is a non-transferable object that could only extend to others either by an explicit contract or by a clear statute. In the present case, neither there is any statute law to support transfer of tenancy on amalgamation nor any agreement executed between the landlord and the tenant to deal with such eventuality. Voluntary act of the tenant making its own position vulnerable would have no bearing on the landlord - Decided against Petitioner.
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2014 (1) TMI 1572
Rejection of rebate claim of Automobile Cess - Claim rejected on the basis of C.B.E. & C. clarification issued vide F. No. 262/01/2007-CX-8, dated 20-3-2007 - Notification No. 19/2004-C.E. (N.T.) - violation of provision of condition No. 2(b) of Notification No. 19/2004-C.E. (N.T.) - Held that:- Government observes that rebate of duty paid on exported goods is to be allowed as per statutory provision contained in the Rules 18 of Central Excise Rules, 2002 read with Notification No. 19/2004-C.E. (N.T.), dated 6-9-2004. The duties to be rebated are specified in Explanation-I of Notification No. 19/2004-C.E. (N.T.) - Similar provision has been made under Section 94 in respect of Education Cess collected as part of customs Duty and under Section 95 Education Cess levied and collected as part of Service Tax. In other words, levy of surcharge under Sections 93, 94 and 95 on respective taxes was the levy for the purpose of Union and was to be utilised by the Union to fulfil the commitment of the Central Government to provide and finance universalised quality of basic education, as has been given out under Section 91 of the Act.
The very fact that the surcharge is collected as part of levy under three different enactments goes to show that scheme of levy of Education Cess was by way of collecting special funds for the purpose of Government project towards providing and financing universalised quality of basic education by enhancing the burden of Central Excise Duty, Customs Duty, and Service Tax by way of charging surcharge to be collected for the purpose of Union. But, it was made clear that in respect of all the three taxes, the surcharge collected along with the tax will bear the same character of respective taxes to which surcharge was appended and was to be governed by the respective enactments under which Education Cess in the form of surcharge is levied & collected.
The Section 93 specifically says that Education Cess levied under Section 91 shall be a duty of excise. Section 91 also stipulates that these shall be levied and collected as surcharge, a cess to be called Education Cess. Hon’ble High Court observed that it was made clear that in respect of these taxes the surcharge collected along with tax will bear the same character of respective taxes to which surcharge was appended and was to be governed by respective enactments under which Education Cess in the form of surcharge is levied and collected. Hon’ble High Court has finally allowed the writ petition and allowed the rebate of surcharge on excise duty appropriated by Union of India as Education Cess for funding universalised quality of basic Education Programme. However, Government notes that the Automobile Cess is not levied and collected as surcharge and also there are no parallel provisions with reference to Automobile Cess as contained in Sections 91, 92 and 93 of Finance Act, 2004. Moreover the Automobile Cess is levied and collected in terms of Notification No. S.O. 247(E), dated 22-3-1990 and not under Central Excise Act, 1944.
Rebate of Automobile Cess levied and collected under Automobile Cess Rules, 1984 and S.O. No. 247(E), dated 22-3-1990 is not admissible under Rule 18 of Central Excise Rules, 2002 read with Notification No. 19/2004-C.E. (N.T.), dated 6-9-2004.
Provisions of Para 1(iii) of the Part I of Chapter 8 of Supplementary Instructions, 2005 and condition 2(b) of Notification No. 19/2004-C.E. (N.T.) stipulate that excisable goods shall be exported within six months from the date on which they were cleared for export from the factory of manufacture or warehouse. In this case initially goods were not cleared for export but it was a stock transfer to their own unit at Hosur on payment of duty. Since the goods are exported from Hosur unit on ARE-1/Invoice, the said goods are cleared for export on the date of preparation of ARE-1 at Hosur unit. Since the goods are exported within six months of their clearance from Hosur unit (date of ARE-1/invoices), the allegation of violation of condition 2(b) of the Notification No. 19/2004-C.E. (N.T.) does not survive and hence, rebate claims cannot be disallowed on this count - Decided partly in favour of assessee.
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2014 (1) TMI 1571
Waiver of pre-deposit of duty and equivalent penalty - petitioner is manufacturing the chassis of the motor vehicles and getting the body built on the chassis from other parties - Payment of the excise duties on the manufactured body of the said vehicle - Duty to be paid by builders - Held that:- petitioner is the manufacturer of the motor vehicle chassis and they sale the chassis of the vehicle on the payment of appropriate excise duty, for which M/s. Tata Motors entered into an agreement with various body builders of the vehicle to pay the duty of the vehicle on the manufactured chassis - merely establishing of a prima facie case, interim order of protection should not be passed. But, if on a cursory glance, it appears that the demand raised has no leg to stand on and it would be undesirable to require the assessee to pay full or substantive part of the demand.
Petition for stay should not be disposed of in a routine manner unmindful of the consequences flowing from the order requiring the assessee to deposit full or part of the demand and then held that there can be no rule of universal application in such matters and the order has to be passed keeping in view the factual scenario involved - hardship to be “undue” it must be shown that the particular burden to observe or perform the requirement is out of proportion to the nature of the requirement itself and the benefit, which the applicant would derive from compliance with it. The word “undue” adds something more than just hardship. It means an excessive hardship or a hardship greater than the circumstances warrant.
Where the petitioner itself knowing about the interim order dated 25-3-2011 passed in its own case and did not just choose to rely upon the said interim order before the Tribunal and invited a detailed order on merits, wherein, in fact the case has been considered on the facts of the case in hand, of the writ petitioner, which is not the position in the order dated 25-3-2011, then no interference is required. However, it is necessary to maintain the judicial discipline by following even the interim order, which has been passed but earlier order had different fat situation, wherein that aspect of the matter has not been taken into consideration and different view also can be taken here in this case. If the Tribunal was not made aware of the order dated 25-3-2011, at the cost of repetition, we would like to observe that the reasons given in the order dated 21-12-2011 are quite different and distinct reasons, which are not be available in the order dated 25-3-2011 - However, Six weeks time is granted for depositing the requisite amount before the Tribunal - Decided against assessee.
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2014 (1) TMI 1570
Cenvat credit availed in favour of naphtha used for the generation of electricity and supplied to their units - Application of Rule 57C - Held that:- assessee used furnace oil in the generation of steam. A part of the steam was transferred to a unit situated outside their factory. Though there is no dispute about the inputs, the fact remains that the steam generated was not used within the factory of production. It is not the case of the assessee that M/s. Futura Industries Limited is a 100% export oriented unit. Rule 57C allows credit of duty in respect of export oriented undertakings. When there is a specific entry in a rule and the said entry pre-supposes that for the purpose of eligibility of credit of duty of inputs, those inputs must be used for manufacture of final products or for any other purpose within the factor of production, the assessee cannot take shelter under a different entry. Admittedly, the assessee has used furnace oil in the generation of steam and the said steam was transferred altogether to a different unit situated outside the factory premises. Therefore, the case of the assessee would come under Rule 57B(1)(iv) - Rule 57C(1)(ii) has to be decided by the CESTAT on merits - The matter is remanded to the CESTAT for consideration regarding the eligibility to claim credit on the basis of Rule 57C(1)(ii) - Decided in favour of Revenue.
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