TAXMAN

Vol. 168, Part 2, for the week of March 22 – March 28, 2008

statutes

q circular

Circular No. 3/2008

-   Finance Act, 2007 - Explanatory Notes on provisions relating to Direct Taxes 

q press release

Income-tax Act

-   Clarification on amendment to section 271 of Income-tax Act 

q Rules/amendment rules

Income-tax (Fourth Amendment) Rules

-   Income-tax (Fourth Amendment) Rules, 2008 - Insertion of rule 125 - Electronic Payment of tax 

Tax Reports

Table of cases

CIT v. Asian Hotels Ltd. (Delhi) 

CIT v. Bareilly Development Authority (All.) 

CIT v. Bharat Heavy Electricals Ltd. (Delhi) 

CIT v. Bilahari Investment (P.) Ltd. (SC) 

CIT v. Guru Nanak Mercantile Co. (Punj. & Har.) 

CIT v. Laxmi Narain (Punj. & Har.) 

CIT v. Ratnasi Deoji Patel (HUF) (Bom.) 

CIT v. Sethi (S.C.) (Raj.)

CIT v. Singhvi (Dr. A.M.) (Raj.) 

Dabwali Transport Co. v. CIT (Punj. & Har.) 

Dy. CIT v. Torqouise Investment & Finance Ltd. (SC) 

Hassan Ali Khan v. Settlement Commission (Bom.) 

Selladurai (V.) v. Chief CIT (OSD) (Mad.) 

V. Ravi Narayanan, In re (AAR - New Delhi) 

subject index

Appellate Tribunal

Powers of

-   Revenue filed writ petition against order of Tribunal permitting assessee to raise an additional ground without approval of Committee on Disputes - Whether revenue could always contest appeal pending before Tribunal on merits and in event of failure, it would be open for it to challenge order passed by Tribunal under section 260A and to urge that Tribunal had erroneously permitted assessee to raise additional ground without approval of Committee on Disputes - Held, yes - Whether therefore, writ petition would not serve any purpose and same should be disposed of accordingly - Held, yes - CIT v. Bharat Heavy Electricals Ltd. (Delhi) 

Assessment

Additions to income

-   Assessment year 2000-01 - Assessee-firm, deriving income from transportation contracts, claimed certain sum as labour expenses - Assessing Officer, finding that assessee had paid labourers at rates more than market rates, partially disallowed amount claimed by assessee - Commissioner (Appeals) as well as Tribunal reduced quantum of disallowance to some extent - Whether in absence of any standard method or chart which might constitute basis to say that norms of computation of labour expenses had been violated, finding of Tribunal, being pure finding of fact, was to be upheld - Held, yes - Dabwali Transport Co. v. CIT (Punj. & Har.) 

-   Assessment year 1993-94 - On basis of some entry in loose papers seized from residence of one ‘A’, additions were made in income of assessee as income from undisclosed source - On appeal, Commissioner (Appeals) noticed that apart from said loose papers, there was no other incriminating material before Assessing Officer; that none of entries in seized documents indicated that amount was received by assessee; and that assessment also suffered from procedural errors inasmuch as assessee was not offered an opportunity to cross-examine ‘A’ - Therefore, Commissioner (Appeals) set aside assessment order and directed Assessing Officer to complete assessment de novo - However, Assessing Officer, without seeking presence of ‘A’, reiterated his earlier assessment order - On appeal, Commissioner (Appeals) deleted addition on ground that Assessing Officer had still not obtained attendance of ‘A’ for being cross-examined by assessee - Tribunal upheld order of Commissioner (Appeals) - Whether Tribunal was justified - Held, yes - CIT v. S.C. Sethi (Raj.) 

Time-limit for completion of

-   Assessment year 1978-79 - By order dated 10-9-1981, Commissioner (Appeals) set aside assessment order made by Assessing Officer - After remand, Assessing Officer sent draft assessment order to assessee on 23-1-1984 and after receiving directions from IAC under section 144B on 19-7-1984, completed fresh assessment on 21-7-1984 - Tribunal set aside assessment order, holding that in terms of section 153(2A), assessment having not been completed within two years of remand, same was barred by time - Whether Tribunal was wrong in not giving benefit of extended period of limitation of 180 days as stipulated under Explanation 1(iv) to section 153(2A) - Held, yes - Whether if period of 173 days, as spent in proceedings under section 144B, was added in normal period of limitation, fresh order passed after remand was clearly within period of limitation as provided for under Act - Held, yes - CIT v. Guru Nanak Mercantile Co. (Punj. & Har.) 

Business expenditure

Allowability of

-   Assessment year 1996-97 - Assessee, an advocate, occupied a rented premises for office use - During relevant assessment year, he carried out certain repairs and renovations in office premises in order to see that said premises was kept in a proper condition and professional activities were carried out effectively and smoothly - Whether since expenditure incurred by assessee was in connection with profession/business and for smooth working thereof, leaving fixed capital untouched, expenditure in question was revenue expenditure and, hence, allowable under section 37(1) - Held, yes - CIT v. Dr. A.M. Singhvi (Raj.) 

Business income

Value of any benefit or perquisite, arising from business or exercise of profession

-   Assessment years 1995-96 and 2000-01 - Whether notional interest on interest-free deposit can be added to income of assessee under section 28(iv) on basis that it may have been earned by assessee if placed as a fixed deposit - Held, no - Assessee received interest-free deposit in respect of shops given on rent - Assessing Officer added notional interest on said deposit in assessee’s income on ground that by accepting interest-free deposit, a benefit had accrued to assessee which was chargeable to tax under section 28(iv) - However, on second appeal, Tribunal held that notional interest on refundable interest free deposit received by assessee in respect of a shop let out on rent was neither taxable as business profit under section 28(iv) nor as income from house property under section 23(1)(a) - Whether Tribunal was justified - Held, yes - CIT v. Asian Hotels Ltd. (Delhi) 

Collection and recovery of tax

Penalty payable when tax in default

-   Assessment years 1982-83 and 1983-84 - Whether assessee having failed to comply with provisions of TDS would be liable to penalty under section 221, notwithstanding fact that TDS and interest if any accrued thereon, have been paid prior to initiation of penalty proceeding - Held, yes - CIT v. Bareilly Development Authority (All.) 

-   Assessment years 1982-83 and 1983-84 - Assessee having failed to comply with provisions regarding TDS, penalty was levied upon it under section 221 - However, on appeal, Tribunal set aside penalty on grounds, that ITO’s discretion to levy penalty had not been fairly exercised; and that no penalty could be levied for non-filing of Form No. 26C - Whether even though no penalty is leviable under section 221(1) for not furnishing Form No. 26C, yet since in instant case penalty proceedings were initiated for violation of provisions of section 201(1), Tribunal had misdirected itself on that issue - Held, yes - Whether, however, Tribunal’s findings, that ITO’s discretion to levy penalty on assessee had not been fairly exercised, being based on appreciation of evidence and material on record, could not be interfered with and, therefore, penalty was rightly deleted by Tribunal - Held, yes - CIT v. Bareilly Development Authority (All.) 

Double Taxation Relief

Where agreement exists

-   Assessment year 1992-93 - Whether in terms of article XI of DTAA dividend income derived by assessee from a company in Malaysia was not liable to be taxed in its hands in India - Held, yes - Dy. CIT v. Torqouise Investment & Finance Ltd. (SC) 

Foreign exchange asset

-   Assessment year 2008-09 - Whether Non-Resident Ordinary (NRO) deposit acquired with convertible foreign exchange in a banking company, which is not a private company as per Companies Act, 1956, shall be treated as a ‘foreign exchange asset’ under section 115C(b) - Held, yes - Whether interest on such NRO deposit shall be treated as investment income under section 115C(c) which is liable to be taxed at rate of 20 per cent under section 115E - Held, yes - Whether, therefore, banks paying interest on such NRO deposit are required to deduct tax at source at rate of 20 per cent - Held, yes - V. Ravi Narayanan, In re (AAR - New Delhi) 

Income escaping assessment

Issue of notice for

-   Assessment years 1987-88 to 1989-90 - Whether non-service of a notice under section 148 on proper person would go to roots and cannot be condoned - Held, yes - Whether where  revenue had not been able to produce any material to show that any notice under section 148 was served upon assessee before framing assessment under section 147, Tribunal was justified in annulling that assessment as invalid - Held, yes - CIT v. Laxmi Narain (Punj. & Har.) 

Income-tax Act, 1961

-   Section 28(iv) 

-   Section 37(1) 

-   Section 90 

-   Section 115C  

-   Section 143 

-   Section 145 

-   Section 148 

-   Section 153 

-   Section 221 

-   Section 245D 

-   Section 254 

-   Section 263 

-   Section 271(1)(c) 

Method of accounting

Change of

-   Assessment years 1991-92 to 1997-98 - Whether every assessee is entitled to arrange its affairs and follow method of accounting, which department has earlier accepted, and it is only in those cases where department records a finding that method adopted by assessee results in distortion of profits, that it can insist on substitution of existing method - Held, yes - Assessee-company was subscribing to chits as its business activity - In context of ‘chit discount’, it was following ‘completed contract method’ of accounting which was earlier accepted by department over several years - For relevant assessment years, Assessing Officer substituted that method by ‘deferred revenue expenditure method’ - Whether since in past department had accepted completed contract method; entire exercise arising out of change of method from completed contract method to deferred revenue expenditure was revenue neutral; and method adopted by assessee did not result in distortion of profits, High court was justified in holding that completed contract method of accounting adopted by assessee was valid, and that department had erred in spreading discount over remaining period of chit on proportionate basis - Held, yes - CIT v. Bilahari Investment (P.) Ltd. (SC) 

Penalty

For concealment of income

-   Assessment years 1982-83 to 1985-86 - Pursuant to a search, assessee filed returns declaring income as noticed from note book seized during search - Assessing Officer completed assessment accepting said income, but levied penalty under section 271(1)(c) by invoking Explanations 1, 4(a) and 5 thereto - Assessee’s case was that note book seized during course of search was books of account maintained by it in regular course of business and, therefore, Assessing Officer was not justified in levying penalty - Commissioner (Appeals) as well as Tribunal deleted penalty - Whether in view of decision of Bombay High Court in Sheraton Apparels v. Asstt. CIT [2002] 256 ITR 20/123 Taxman 238 holding that books recording facts, but not maintained for computation of income, could not be said to be books of account, questions of law did arise out of order of Tribunal - Held, yes - CIT v. Ratnasi Deoji Patel (HUF) (Bom.) 

Revision

Of orders prejudicial to interest of revenue

-   Assessment year 2001-02 - During relevant assessment year, assessee constructed a building - Assessing Officer allowed 10 per cent rebate for personal supervision while computing value of construction of said building - Chief Commissioner set aside assessment order under section 263 on ground that percentage of rebate given was not correct - Admittedly, before passing said order, no personal hearing was given to assessee and there was, thus, clear violation of principles of natural justice - Whether on that ground itself, impugned order was liable to be set aside and matter should be remanded back to Chief Commissioner - Held, yes - V. Selladurai v. Chief CIT (OSD) (Mad.) 

Settlement Commission

Procedure on application under section 245C

-   Assessment years 2000-01 to 2007-08 - Whether Settlement Commission can treat an application for settlement as invalid meaning thereby non est, if applicant has not made a true and full disclosure - Held, yes - Whether once decision is taken by Settlement Commission, which acts in a quasi judicial capacity, it is for applicants to point out that there has been either a failure to exercise jurisdiction or that exercise of jurisdiction is based on an assumption not warranted or that order suffers from an error of law apparent on face of record when it holds application to be invalid and it is only in those cases, that High Court will exercise its extraordinary jurisdiction subject of course to discretion it has - Held, yes - During search conducted at residential premises of petitioners, husband and wife, certain document pertaining to evasion of foreign exchange were found - Petitioners filed income-tax returns disclosing income from horse racing - Subsequently, they filed applications for settlement before Settlement Commission - Settlement Commission constituted Special Bench which rejected applications holding that same did not contain full and true disclosure of income/wealth of petitioners - Petitioners challenged rejection of their applications mainly on grounds that there was failure of principles of natural justice and no sufficient opportunity was given to them as documents relied upon by revenue were made available to them only at time of hearing; that reasons for constitution of Special Bench were not given; and that rejection was without jurisdiction - Whether since all documents and statements relied upon were made available to petitioners and they had dealt with said documents, it could be said that there was a failure of principles of natural justice and fair play - Held, no - Whether discretion to constitute a Bench, if there be a case which requires to be decided by Special Bench, is that of Chairman of Commission; since petitioners had themselves set out nature and circumstances of case and complexities of investigations which were involved and Chairman borrowed same phraseology to constitute Special Bench, it could not be said that action of Chairman was without jurisdiction or exercise of power was illegal - Held, yes - Whether when during search prima facie material of evasion of foreign exchange had come on record and same was prima facie contrary to disclosed source of income, i.e., horse racing, order of Settlement Commission rejecting applications could not be said to have suffered from either want of jurisdiction, excess of jurisdiction or disclosing an error of law apparent on face of record - Held, yes - Hassan Ali Khan v. Settlement Commission (Bom.) 

Wealth-tax

Settlement Commission

Procedure on application made under section 29C

-   Assessment years 2000-01 to 2007-08 - Whether in view of facts under heading ‘Settlement Commission - Procedure on application under section 245C’, once Commission found that applications filed under Income-tax Act, 1961 were not bona fide, it was open to Commission, even in respect of an application under Act, to treat application as invalid - Held, yes - Hassan Ali Khan v. Settlement Commission (Bom.) 

Wealth-tax Act, 1957

-   Section 22D 

magazine

features

q finance bill, 2008

SURENDRA BHARGAVA, Chief Commissioner/RIDHI KARAN, Chartered Accountant

-   Amendment in section 195 : Confusion Continues 

NARAYAN JAIN, Advocate and Tax Consultant

-   Relief in personal income-tax will help to develop tax culture 

V. GANGADHARAN, Asstt. Officer (Taxes)

-   Budget gains confidence of both taxpayers and consumers 

T.C.A. SANGEETHA, Advocate

-   Finance Bill, 2008 : An Overview 

SUBHASH CHANDRA SINGHAL, Chartered Accountant

-   Violative of liberty - Proposed amendment in section 292BB 

SRIKUMAR BANERJEE, Chartered Accountant

-   Budget 2008-09 - Major tax Proposals 

B.N. DAS, Consultant

-   Budget Bonanza 

RAJIV TULI, Chartered Accountant

-   Budget 2008-09 : Impact Analysis