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2009 (12) TMI 963
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... ... ..... ,73,680/- is too deleted.” 7. We have considered the rival contentions and found that assessee’s claim on account of discount and rebate pertains to bills raised on behalf of Siti Cable Network Limited. During the year, certain credit notes were issued by Siti Cable to the assessee’s customers against whom billing was raised by the assessee company. Accordingly, these amounts were received less by the assessee company. This was in the nature of rebate and discount claimed by the assessee. Full details of such rebate were mentioned in the books of account and AO has not pointed out any defect or deficiency in the accounts, accordingly no adverse inference can be drawn against these expenses claimed under the head rebate and discount. The finding of CIT(A) remained uncontroverted, we therefore do not find any reason to interfere in the same. 8. In the result, the appeal of the Revenue is dismissed. Decision pronounced in the open Court on 31st December, 2009.
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2009 (12) TMI 962
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... ... ..... h the same and had remained unchallenged by the department. From treatment accorded by the assessee to these shares, the evident intention of the assessee was to hold shares for a long period of time and to sell them at an appropriate stage in order to earn income in the nature of dividend and capital appreciation. It is also undisputed that the earnings from the sales of shares were used for payment of loan. In such circumstances, it was erroneous to hold that the assessee kept the shares for trading purposes. As per the AO, he did not give any forceful reason for treating the profit/loss arising from the sale of shares as profits and gains of the assessee from business or profession. The learned CIT (A), in our view, correctly appreciated this factual matrix and it was only thereupon he ordered the AO to tax the profit/loss on sale of shares during the year as capital gain and not as profits and gains from business or profession” No question of law arises. Dismissed.
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2009 (12) TMI 961
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... ... ..... on 2(22)(e) of the Act and therefore the said addition is deleted. 11. The assessee has also raised grounds relating to reopening of the assessments under Section 147 for the assessment years 2000-2001 and 2001-2002. As the issues have been decided on merits, the grounds relating to reopening have become redundant. There are not adjudicated. 12. The assessee has further raised grounds for the assessment year 2005-2006 relating to the levy of interest under Sections 234A, 234B and 234C of the Act. These are only consequential in nature, which do not call for adjudication. The assessee has raised another ground for Page - 7 M/s.Subhalachal Print & Pack Vs. ACIT (6 Appeals) A.Y.2005-2006 against the proposal to levy penalty under Section 271(1)(c) of the Act. We will only say that the said ground is premature. 13. In result, these appeals filed by the assessee are treated as allowed on the merits of the issues. Order pronounced on Wednesday, this 16th day of December, 2009.
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2009 (12) TMI 960
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... ... ..... 239) E.L.T. 385 (S.C.), the matter is remitted to the High Court for de novo consideration in accordance with law. Civil Appeal stands disposed of accordingly. No order as to costs.
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2009 (12) TMI 959
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... ... ..... on separate sheets kept in the record of Civil Misc. Writ Petition (Tax) No. 1190 of 2008 (M/s. A.C.P.L Jewels Private Ltd Vs. Union of India and others). 01.12.2009
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2009 (12) TMI 958
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... ... ..... bsequently, the Bombay High Court has taken a different view that the said case was not available when the matter was decided by this Court in Rajanikant' s case (supra). Hence, all these cases require reconsideration by this Court. Rajanikant's case (supra) has been rendered by this Court on 10th Sept., 2007, whereas the Bombay High Court judgment has been rendered on 7th May, 2009 The Bombay High Court judgment is CIT vs. Ajanta Pharma Ltd. (2009) 223 CTR (Bom) . Whatever may be the reasoning given by the Bombay High Court, this Court has followed the decision of the Supreme Court in Surana Steels (P) Ltd. vs. Dy. CIT (1999) 237 ITR 777(SC) and also the judgment of the Supreme Court in Apollo Tyres Ltd. vs. CIT ((2002) 255 ITR 273(SC). The decision of our High Court in 2007 is squarely binding on us. Hence, following the decision of CIT vs. Rajanikant Schnelder & Associates (P) Ltd. (supra), these tax case appeals, at the instance of the Revenue, are dismissed.
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2009 (12) TMI 957
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... ... ..... ground that the Balance Sheet of SPSA was not made available to him to verify its creditworthiness. The assessee has filed the Balance Sheet of SPSA which conclusively proves its net worth the figures of which were earlier given to the Assessing Officer by the assessee. Under these circumstances the creditworthiness of SPSA, in our opinion, is substantiated. The identity of the party was never in doubt. The genuineness of the transaction was also never in doubt. Now that the assessee has proved all the three criteria i.e., the identity, creditworthiness of the party as well as the genuineness of the transaction, therefore, the addition of ₹ 2,26,72,557 cannot be added u/s. 68 of the Act. In this view of the matter we set aside the order of the CIT(A) and direct the Assessing Officer to delete the addition. The grounds raised by the assessee are accordingly allowed. 15. In the result, the appeal filed by the assessee is allowed. Order pronounced on 11th December, 2009.
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2009 (12) TMI 956
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... ... ..... sentative for the assessee also agreed in the course of arguments that the matter may be restored back to the file of the Assessing Officer for a fresh decision as per rule 8D of the Income-tax Rules. Accordingly, we set aside the order of the learned Commissioner of Income-tax (Appeals) on this issue and restore back the matter to the file of the Assessing Officer for a fresh decision as per rule 8D of the Income-tax Rules, 1962, and the Assessing Officer should pass necessary order as per law after providing adequate opportunity of being heard to the assessee. 12. Regarding ground No. 3, no argument was advanced by the learned authorised representative for the assessee and hence the same is considered as not pressed and dismissed accordingly. 13. Ground No. 2 of the assessee stands allowed for statistical purposes. 14. In the result, the appeal of the assessee stands partly allowed for statistical purposes. 15. The order pronounced in the open court on 17th December, 2009.
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2009 (12) TMI 955
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... ... ..... elevant material on record to controvert the findings of the learned CIT (Appeal) and no mistake could be pointed in the order of the learned CIT (Appeal). The Tribunal, therefore, confirmed the order of the CIT (Appeal). Since there is concurrent finding of facts, no substantial question of law arises in the order of the Tribunal. 3. So far as the 2nd question is concerned, the Tribunal has observed that there was no nexus between the investment made in the partnership firms and secured loans taken by the assessee. The Revenue could not bring any positive and relevant material on record to controvert the said finding of the learned CIT (Appeal). The Revenue also could not show that the secured loans were utilized by the assessee other than for the business purpose of the assessee. 4. These all are the findings of facts by two authorities. It cannot be said that any substantial question of law arises out of the order of the Tribunal. This Tax Appeal is, therefore, dismissed.
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2009 (12) TMI 954
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... ... ..... y comparing it with the bank loans which follow strict norms in granting Loans. He thus strongly supported the Order of the learned CIT(A). 15. We have carefully considered the rival submissions and perused the record. It is not in dispute that the assessee paid interest on unsecured loans (obtained from outsiders) and interest paid thereon, varying from 12 to 18 to outsiders, was claimed as deduction and accepted by the Assessing Officer. Such being the case, merely because few Loans were taken from the "relatives", interest paid 18 cannot be held to be excessive and unreasonable. Having regard to the facts and circumstances of the case, we do not find any infirmity in the Order of the learned CIT(A). Accordingly, ground No.2 is rejected. Other grounds urged before us are general in nature and therefore, do not require independent consideration. 16. In the result, appeal filed by the Revenue is dismissed. Order pronounced in the open Court, on this the 17.12.2009.
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2009 (12) TMI 953
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... ... ..... r loss has been claimed by it. Assessing Officer has doubted the transaction of sale only. The stock to the extent of sale has been extinguished from the books. In such situation what the Assessing Officer would give the treatment of non availability of investment in the books of assessee to the extent sales have been claimed. Both these things would set off with each other and no addition ultimately could be made because the moment sale is doubted the status of the shares has to be restored in the books of assessee because it has come from the opening stock. But in fact shares are not available with the assessee, in such situation no addition by doubting the sales in this year should be made, more so that only on the basis of surmises and apprehension. The learned CIT(Appeals) has considered the issue in detail and has rightly deleted the addition. 8. In the result, the appeal as well as the cross-objection are dismissed. Decision pronounced in the open court on .11.12.2009
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2009 (12) TMI 952
Computation of Profit - Offshore supply of material/equipment contract - deletion of addition made by the AO by computing profit at 5% of the turnover arising from the supply of equipment to GPEC - assessee-company entered into two contracts - supply of material/equipment for consideration of DM 713 millions - design and engineering of erection material/equipment for consideration of DM 32 millions - AO noted that the assessee has a PE in India during the year under consideration also and as a result of that, the payments received or receivable in GPEC contracts for supplies were held to be taxable. ld CIT(A) deleted the addition.
HELD THAT:- We have gone through the copy of agreement with GPEC, which is available on record. Albeit in this year the party with whom the contracts were entered, namely GPEC, is different, as against M/s BPL system and Project Limited, with whom the contract was entered into the preceding year yet the major terms of the contract, in so far as they are relevant for our decision on this issue, are mutatis mutandis similar. The learned Departmental Representative failed to invite our attention towards any clause of the instant contract by which departure is required from the view taken by the Tribunal in the immediately preceding year.
We find that the Central Board of Direct Taxes vide Circular No.7 of 2009 dated 22.10.2009 has withdrawn Circular No.23 dated 23.7.169 and also Circular No. 786 dated 7.2.2000. According to para 3 of this Circular No.7 of 2009 the earlier circular No.23 dated 23.7.1969 is withdrawn "with immediate effect". Similar is the fate for Circular No. 786. It, therefore, becomes clear that the Circulars on which the Tribunal has placed reliance while deciding the case for assessment year 1997-98 in assessee's own case hold good for the instant year as well.
It is axiomatic that a Circular in operation through the assessment year 1998-99 cannot be held to be in-operational simply by reason of the fact that it has been withdrawn in the year 2009. The withdrawal of such Circulars will be effective only after the said date of 22 October, 2009 by which these Circulars have been withdrawn 'with immediate effect'. Therefore, We are reminded of the Full Bench judgement of the Hon'ble Kerala High Court in CIT vs. B.M. Edwards, India Seafood [1979 (2) TMI 70 - KERALA HIGH COURT].
In the light of the ratio decidendi of the aforenoted judgment, we hold held that Circular no. 23 dated 23.7.1969 and 786 dated 7.2.2000 which were operative in the assessment year under consideration are binding even if withdrawn by the later Circular of the year 2009.
We hold that the income from the offshore supplies is not taxable in the hands of the assessee under the regular provisions of the Act. In such a situation there is no need to examine the provisions of DTAA for ascertaining whether there is a permanent establishment of the assessee in india or not. For the foregoing reasons, we are of the considered opinion that there is no infirmity in the impugned order on this issue requiring any interference. These grounds, therefore, stand dismissed.
Taxability of income on accrual - Both the sides are in agreement that similar issue came up before the Tribunal in assessee own in assessment year 1997-98 and other years. following the view taken in assessee own case for several other years starting from 1990-91 onwards has held that the fees for technical services should be taxed only on receipt basis and not on accrual basis. Respectfully following the precedents we allow this ground of appeal.
Protective addition - whether the income was to be taxed on an accrual basis or on a cash basis - computation of royalty and fees for technical services on accrual basis against the income on receipt basis - AO held that such income was to be taxed on accrual basis. CIT(A) approved the action of the AO.
HELD THAT:- It is observed that the Tribunal has consistently held that the amount of royalty and fees for technical services is to be taxed on receipt basis and not on accrual basis. Similar finding has been given above in respect of the instant assessment year as well. As a natural corollary, no fault can be found in the action of the Revenue Authorities in considering the amount as taxable on receipt basis. Consequently the protective addition made by the AO is held to be substantive. This ground taken by the assessee is dismissed.
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2009 (12) TMI 951
Unexplained cash credit - transansaction of shares unexplained - bogus and sham transaction -Addition made as assessee had failed to discharge its onus to prove the genuineness of the transaction - HELD THAT:- We find ourselves in favour of the submission made as the assessee had produced confirmations which would clearly demonstrate it has discharged its initial burden.
The identity of M/s. Yadav and Company, by filing their confirmation and their assessment particularly Genuineness of the transaction by pointing out that the assessee had sold shares to M/s. Yadav and Company in the immediately preceding year (which has been accepted by the Department) and that the payment received during the relevant previous year was against the debt due from M/s. Yadav and Company and Creditworthiness of the creditor by pointing out that the amount was received by way of cheques drawn on the bank account.
The initial burden thus discharged, it was for the revenue to establish that the transaction in question was bogus. This would be so even if there is a denial by the creditors that the credits were not genuine as held by the Supreme Court in CIT v. Orissa Corpn. (P.) Ltd.1986 (3) TMI 3 - SUPREME COURT] - Mere denial by Yadavs that account in question was not operated by them would not automatically lead to the inference that assessee deposited in the said account and, therefore, it became its unaccounted income.
When the premises of M/s. Yadav and Company were searched by the Department in 2002 and the statements of aforesaid two persons were recorded, it is clear that Yadav and Company was very much in existence. More interestingly, M/s. Yadav and Company even assessed to Income-tax. In the case of assessee, the assessment was completed in December, 2003. In such a scenario, it would not have been difficult for the Assessing Officer to find the whereabouts of Yadavs particularly having regard to the statement of the assessee that it had no dealing with M/s. Yadav and Company after assessment year 2000-01 and was thus unaware of its present whereabouts. Live link between the bank account of M/s. Yadav and Company and the assessee has not been established. - Decided in favour of assessee
Whether the ITAT should have remitted the matter back to the Assessing Officer, if it was of the view that proper opportunity was not afforded to the assessee? - We feel that there was a bona fide confusion in the mind of the Assessing Officer regarding the onus viz., whether it was obligation of the assessee or the Assessing Officer to produce Sh. O.P. Yadav and Sh. Mohinder Singh Yadav. Therefore, in the interest of justice matter needs to be remitted back to the Assessing Officer to enable him to produce the Yadavs for cross-examination by the assessee. AO shall undertake fresh exercise as per the observations contained in the order of ITAT and this order and addition would be made only if those conditions are satisfied.
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2009 (12) TMI 950
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... ... ..... aw requires to be reframed and accordingly, it is refrained as follows "Whether the AO was correct in rejecting the claim of the assessee that set off of loss and unabsorbed depreciation is to be reduced from the total income of the assessee or not ?" 12. While the similar issue having been considered by the Hon'ble Supreme Court in E.K. Lingamurthy's case (supra) and the issue being no more res Integra, this substantial question of law reframed by us hereinabove requires to be answered in favour of the assessee and against the Revenue. However, with regard to the quantification of the said entitlement, the same requires to be considered by the AO on the basis of the materials available before the AO and as such for the said limited purpose of quantifying the entitlement of set off of loss and depreciation, the matter is remitted to the AO to redo the exercise and arrive at the total taxable income. Accordingly, this appeal is allowed. No order as to costs.
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2009 (12) TMI 949
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... ... ..... paid tax for certain amount of additions which should not have been considered for the respective assessment years. Therefore, even though not in the form of a formal penalty, the assessee has suffered tax which might be more than necessary. This additional suffering in the hands of the assessee has not been considered by the lower authorities in a proper perspective. They have proceeded to levy the penalty in a mechanical manner treating the penalty as an inevitable consequence of additions made in the quantum assessments. 06. Therefore, in the facts and circumstances of the case, taking into consideration the additional injury suffered by the assessee in the quantum assessments itself, we find that it is not fair to levy penalties on the assessee. Accordingly, we delete the penalties levied for all these seven assessment years under appeal. 07. In result, these appeals filed by the assessee are allowed. Order pronounced on Monday, the 14th day of March, 2011, at Bangalore.
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2009 (12) TMI 948
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... ... ..... itled to deduction under s. 80P of the IT Act, 1961. The learned counsel for the assessee stated that in the case of Punjab State Co-op. Agri. Dev. Bank Ltd. (supra), the AO disallowed similar claim and the CIT(A) deleted the disallowance. On this issue, the Tribunal, Chandigarh Bench in its order dt. 24th Sept., 2004 passed in ITA No. 435/Chd/2009 deleted the disallowance and dismissed the appeal of the Revenue. Respectfully following the judgment of the Chandigarh Bench (supra), we allow this ground in favour of the assessee and deleted the addition in dispute. 13. As we have stated in the beginning that in the present two appeals the issue in dispute are identical, we have deleted the addition in dispute in ITA No. 419/Asr/2009. Therefore, being similar addition involved in ITA No. 418/Asr/2009 in the case of The Faridkot Primary Co-op. Agrl. Dev. Bank Ltd., Faridkot, the same is hereby deleted. 14. In the result, both the appeals filed by different assessees are allowed.
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2009 (12) TMI 947
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... ... ..... t the assessee in turn had made a claim before the Central Government. When the Central Government has turned down such requests as the Interim order has to be honoured and if such amount paid pursuant to an Interim order, the department cannot contend that such payment cannot be allowed as deduction since final award is yet to be passed. 3. According to us, if any, amount is paid pursuant to an Interim order, would be subject to the final award of the Arbitration proceedings and in the Arbitration proceedings, if ultimately held that the assessee is not liable to pay any amount and the amount of ₹ 52.84 lakhs or any sum paid by the assessee has to be recovered from the Sub-contractor, the assessee is bound to brought the same into the account and therefore the arguments advanced by the learned counsel for the revenue cannot be accepted. 4. In the result, we do not see any substantial questions of law that arises in this appeal. 5. Accordingly, the appeal is dismissed.
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2009 (12) TMI 946
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... ... ..... aken on board. On 15th May, 2009, while issuing notice we had directed stay of proceedings, but inadvertently not indicated stay of what recovery proceedings. Let it be clarified that there will be stay of recovery proceedings relating to transit fee.
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2009 (12) TMI 945
Nature of receipt/income - sales tax incentive - present scheme is the New Package Scheme of Incentives 1993 of Government of Maharashtra - denial of claim of exclusion of sales-tax incentive on the ground that it is a capital receipt - HELD THAT:- FAA has come to a factually incorrect conclusion that the assessee has brought sales-tax incentive by way of interest free unsecured loan and it had to repay the sales-tax liability after 10 years as per the repayment schedule.
In view of the discussion we hold that the issue is squarely covered by the Special Bench of the Tribunal in the case of CIT vs Reliance Industries Ltd [2003 (10) TMI 255 - ITAT BOMBAY-J] and concluded that the receipt in question is capital receipt.
Argument of the revenue that sales-tax is not separately charged in the invoices - When a consolidated amount is charged in an invoice it cannot be said that it does not contain sales-tax component. Even if a separate account has been maintained for the sales-tax collected and paid, it is not correct to say they were not in the revenue field and are not reckoned while computing profit & loss of the concern. A disclosure by the auditor that separate account has been maintained for sales-tax recovered and paid does not mean that the effect of the sales-tax has not been considered in the accounts of the assessee. It is well settled that the entries in the books of account are not determinative of the fact whether a deduction is allowable or not. Thus, this objection of the revenue is rejected.
Disallowance of depreciation by reduction of notional tax on capital gain on an exemption allowed u/s 54G from the actual cost of the plant and machinery capitalized in the said assessment orders by invoking Explanation 10 to section 43(1) and thereafter computing the written down value - assessee alternatively, aggrieved at the non reduction of the same from the cost of land and building instead of plant and machinery - HELD THAT:- Section 54G exempts from capital gain on transfer of assets, in cases where an industrial undertaking is shifted from an urban area to a non urban area subject to fulfillment of certain conditions specified in that section.
An exemption from payment of capital gains tax granted u/ 54G cannot by any stretch of imagination be called a subsidy or grant or reimbursement. Such exemption cannot be said to have been granted by the State or Central Government to meet directly or indirectly a portion of the cost or the asset. For this sole reason, the entire theory made out by the assessing officer has to be quashed as devoid of merit. We are unable to comprehend how such strange, thoughts and propositions crept into the mind of the assessing officer.
The benefit u/s 54G was admittedly given to the assessee during the assessment years 1995-96 and 1996-97. Explanation 10 to sub section 43(1) was brought into the statute only wef 01-04-1999 and even in this Explanation, in our considered opinion, there is no possibility of anybody coming to a conclusion that actual cost of the asset as accepted by the revenue in the assessment years 1995-96 and 1996-97 have to be disturbed while doing the assessment for the assessment year 2003-04. The proposition suffice to say, is devoid of any logic. If such propositions are accepted, it will lead to a situation where any exemption granted under various provisions of the Income-tax Act for the payment of tax including depreciation, investment allowance etc. would be taken as a subsidy, grant or reimbursement and can be considered for the reduction of cost of asset.
CIT(A) exercise of his powers and setting aside the matter to the file of the assessing officer for fresh adjudication - CIT(Appeals) setting aside the matter with regard to factory power expenses, power house expenses,expenses incurred on maintenance of depot shed and non grant MAT credit brought forward from earlier years to the file of the A.O - HELD THAT:- We find that the CIT(A) has in erroneous exercise of his powers and wrongly set aside the matter to the file of the assessing officer for fresh adjudication though he had no power to do so consequent to the amendment brought into the Act with effect from 01-06-2001 by Finance Act, 2001 whereby section 251(1)(a) has been amended and the words "or he may set aside" have been deleted. We also find that while the CIT(A) agrees with the submissions of the assessee, he set aside the matter to the file of the assessing officer for fresh adjudication which is, in our considered opinion, not proper.
In any event, as the first appellate authority has no power to set aside the matter, we reverse his order to that extent and remit the matter back to his file for fresh adjudication in accordance with law. The assessee is at liberty to furnish any additional material in support of his claims and the first appellate authority is directed to admit such material and if necessary obtain a remand report from the assessing officer and dispose of these grounds on merits.
The first appellate authority shall not be influenced by the fact that in the set aside proceedings the assessee has not been able to present himself before the AO. With these observations we dispose of grounds 5, 6 9 & 10 of the assessee.
Ad-hoc disallowance of sale promotion expenses - Addition made there would be a possibility that some of the expenses would have not been incurred - HELD THAT:- Assessee provided complete break up of all the details in the course of assessment proceedings and also an extract of the ledger account in respect of the details provided. The assessing officer has not asked for any specific detail or proof in the nature of any particular bill from the assessee during the assessment proceedings. No explanation regarding allowability or reasonableness of the expenses was asked for during the course of assessment proceedings. On this factual matrix, we hold that the adhoc disallowance is nothing but a sheer surmise and such disallowance cannot be sustained
Disallowance of repair and expenses at head office - Expenditure largely been incurred for replacement of tiles, replacement of glass windows, doors panels etc - HELD THAT:- The nature of these expenses clearly suggest that they are in the revenue field as no asset of enduring nature can be said to have come into existence by incurring of this expenditure. Thus, We find that the assessee has rightly relied upon the judgment in the case of New Shorrock Spinning & Mfg Co Ld vs IT [1956 (2) TMI 54 - BOMBAY HIGH COURT] ; Cultural Enterprises Corporation vs CIT [1992 (1) TMI 81 - CALCUTTA HIGH COURT] and claimed that this expenditure has been wrongly disallowed. In the case of New Shorrock Spinning held that the test that must be applied is that as a result of the expenditure which is claimed as an expenditure for repairs, what is really being done is to preserve and manage an already existing asset. Respectfully applying these decisions to the facts of this case, we allow the ground of the assessee.
Levy of Interest u/s 234D - Section 234D was introduced with effect from 01-06-2003 and hence applicable for the assessment year 2004-05 as held in the case of ITO vs Ekta Promoters Pvt Ltd [2008 (7) TMI 452 - ITAT DELHI-E]. Respectfully following the same we allow this ground of the assessee and direct the AO not to levy interest u/s 234D.
Levy of Interest u/s 234B and 234C - We respectfully apply the decision in the case of South Eastern Coal Fields Ltd [2002 (2) TMI 344 - ITAT NAGPUR] and direct the AO to compute interest u/s 234C as per the income disclosed in the revised return. Coming to levy of interest u/s 234B we hold that it is consequential in nature. In the result, ground 12 is allowed in part.
In the result, appeal filed by the assessee is allowed in part.
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2009 (12) TMI 944
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... ... ..... uld be made up in rectification proceedings under Section 154 of the Act. 5. In view of the above findings, we allow the appeal by reversing the order of the Tribunal and by restoring in principle the levy of interest under Section 234B(3) of the Act. However, we notice that interest is demanded under Section 234B(3) on the entire balance demand of tax raised in reassessment proceedings. Interest could be demanded under Section 234B(3) on the shortfall of advance tax paid. In other words, advance tax payable should be first determined based on reassessment and reduce therefrom actual amount of advance tax paid and interest should be demanded only on the differential amount, that too, from the date following the regular assessment till date of completion of the assessment under Section 147. If there is mistake in the calculation of interest under Section 234B(3), there will be direction to the officer to correct the same in tune with the scheme of the Section as stated above.
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