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Landmark Rulings

All landmark rulings

21,722 rulings

  1. Direct Tax ·ITAT Amritsar · 19 Aug 2013
    Capital Gain - JDA- Consideration accrued is also relevant, to be taxed once transfer of the capital asset takes place. Court injunction cannot be said not willing to perform its obligation. Assessee’s plea that the possession was to be given only at the time of registration of the JDA, is not correct. Once irrevocable power was given then it cannot be said that the possession was not given.

    Shri Satnam Singh Kainth Ex-MP vs vs Income Tax Officer

    (2014) TaxCorp(LJ) 2759 (ITAT-AMRITSAR)

  2. Direct Tax ·ITAT Delhi · 11 Apr 2014
    Determining the NRI status – Exceeding 182 days due to illegal impounding of passport - over stay caused by such untenable restriction of movement out of India should be excluded while calculating the no. of days of stay in India.

    Shri Suresh Nanda vs ACIT

    (2014) TaxCorp(LJ) 2758 (ITAT-DELHI)

  3. Direct Tax ·ITAT Panaji · 04 Apr 2014
    S. 2(47) - Capital Gain – Date of Transfer - Wherever a Rectification Deed is executed, it rectifies the original transaction and is applicable from the date when the original transaction took place. The Sale Deed in this case was originally executed and registered on 4.7.2008. Therefore, the transfer of the land has taken place during the A.Y 2009 -10.

    Income-tax Officer vs Smt. Myra Muriel Paul

    (2014) TaxCorp(LJ) 2757 (ITAT-PANAJI) · Section 2(47)

  4. Direct Tax ·ITAT Mumbai · 07 Apr 2014
    S. 40(a)(ia) - Prospectively or Retrospectively - Voluntarily offered - Tax deducted from labour charges u/s 194C - Tax paid before the due date

    Shri Vijay G. Mandave vs Income Tax Officer

    (2014) TaxCorp(LJ) 2756 (ITAT-MUMBAI) · 40(a)(ia)

  5. Direct Tax ·ITAT Cochin · 07 Apr 2014
    Violation of the provisions u/s 13(1)(c) - Trust uses its income for construction of building on the land belonging to one of the trustees amounts to applying the income of the trust for the benefit of the trustee which is certainly falls under section 13(1)(c) of the Act.

    Assistant Director of Income Tax (Exemptions) vs Natya Sankalpaa

    (2014) TaxCorp(LJ) 2755 (ITAT-COCHIN) · 13(1)(c)

  6. Direct Tax ·Gujarat High Court · 31 Mar 2014
    Section 14A would have no applicability in relation to deductions to be made while computing total income under Chapter IV

    CIT vs BANASKANTHA DIST.CO.OP. MILK PRODUCERS' UNION LTD

    (2014) TaxCorp(LJ) 2754 (HC-GUJARAT) · 14A

  7. Direct Tax ·Bombay High Court · 25 Mar 2014
    Write-off of irrecoverable advances is not a “transfer” and the loss cannot be claimed as a capital loss u/s 45

    Crompton Greaves Limited vs Deputy Commissioner of Income Tax

    (2014) TaxCorp(LJ) 2753 (HC-BOMBAY)

  8. Direct Tax ·ITAT Cochin · 28 Mar 2014
    The usage of the land by the purchaser not relevant factor to find whether the land is agricultural land or not?

    JCIT vs Cochin Malabar Estates & Industries Ltd

    (2014) TaxCorp(LJ) 2752 (ITAT-COCHIN)

  9. Direct Tax ·Karnataka High Court · 24 Mar 2014
    Chapter XIV-B do not preclude AO to proceed against assessee by issuing notice u/s 148

    Gudwill Housing Limited vs ITO

    (2014) TaxCorp(LJ) 2751 (HC-KARNATAKA) · 158BD

  10. Direct Tax ·AP High Court · 22 Jan 2014
    Application of fund for construction of the building, is not the charitable activity.

    Kamma Sangham vs The Director of Income Tax (Exemptions)

    (2014) TaxCorp(LJ) 2750 (HC-AP)

  11. Direct Tax ·Allahabad High Court · 13 Mar 2014
    No disallowance u/s 40(a)(ia) as 'securities' stood excluded from the definition of "brokerage or commission" under Section 194-H. Hon`ble high court rejects submission of the revenue to adopt a restrictive interpretation because unless this were done, would exclude a large number of transactions from the ambit of Section 194-H where 'commission or brokerage' is paid in relation to any transaction relating to securities.

    CIT vs Tandon & Mahendra

    (2014) TaxCorp(LJ) 2749 (HC-ALLAHABAD) · 40(a)(ia)

  12. Direct Tax ·Gujarat High Court · 11 Mar 2014
    S. 80-IB(10): If developer does not (without just cause) develop to full extent of FSI, a part of the sale proceeds has to treated as being for sale of FSI and denied s. 80-IB(10) deduction

    THE COMMISSIONER OF INCOME TAX-I vs MOON STAR DEVELPERS

    (2014) TaxCorp(LJ) 2748 (HC-GUJARAT) · 80IB(10)

  13. Direct Tax ·Gujarat High Court · 25 Mar 2014
    The effect of s. 80IA(9) is that s. 80-IA deduction has to be reduced for s. 80HHC deduction in all cases and not only when the combined deduction exceeds the profits

    COMMISSIONER OF INCOME TAX vs ATUL INTERMEDIATES

    (2014) TaxCorp(LJ) 2747 (HC-GUJARAT) · 80IA(9), 80HHC

  14. Direct Tax ·Kerala High Court · 04 Mar 2014
    Factual situation relevant for allowing deduction under section 80-IB, not approved plan

    CIT vs ABAD CONSTRUCTIONS PVT. LTD

    (2014) TaxCorp(LJ) 2746 (HC-KERALA) · 80IB(10)

  15. Direct Tax ·AP High Court · 29 Nov 2013
    Reassessment - Notice after four years - Conditions must be reflected in notice itself - Conditions that officer must be satisfied that there has been an escapement in assessment of income, which is chargeable to tax because of failure by assessee to file return under section 139. Notice and consequential steps not valid.

    Tecumesh Products India Pvt. Ltd vs The Assistant Commissioner of Income Tax

    (2014) TaxCorp(LJ) 2745 (HC-AP) · Income-tax Section 147, 148

  16. Direct Tax ·Karnataka High Court · 18 Jan 2014
    Criminal proceedings u/s 276B are independent of recovery proceedings under Sec 201(1) and 201(1A).

    KINGFISHER AIRLINES LTD and Sri VIJAY MALLYA vs INCOME TAX DEPARTMENT

    (2014) TaxCorp(LJ) 2744 (HC-KARNATAKA) · 276B

  17. Direct Tax ·Karnataka High Court · 18 Jan 2014
    Criminal proceedings u/s 276B are independent of recovery proceedings under Sec 201(1) and 201(1A).

    KINGFISHER AIRLINES LTD and Sri VIJAY MALLYA vs INCOME TAX DEPARTMENT

    (2014) TaxCorp(LJ) 2743 (HC-KARNATAKA) · 276B

  18. Direct Tax ·ITAT Cochin · 31 Mar 2014
    Second Proviso introduced by Finance Act, 2012 w.e.f 01-04-2013 to section 40(a)(ia) operates prospectively and not retrospectively.

    Sea Food Park India Limited vs Dy.CIT

    (2014) TaxCorp(LJ) 2742 (ITAT-COCHIN) · Income Tax Section 40(a)(ia)

  19. Direct Tax ·ITAT Pune · 06 Jan 2014
    Second proviso to Sec 40(a)(ia) inserted w.e.f. April 1, 2013, being clarificatory in nature, should have retrospective application.

    ITO vs Gaurimal Mahajan & Sons

    (2014) TaxCorp(LJ) 2741 (ITAT-PUNE) · Income Tax Section 40(a)(ia)

  20. Direct Tax ·Delhi High Court · 28 Mar 2014
    Hasty Recovery action may be treated as Contempt – Bombay HC to AO

    A. T. KEARNEY INDIA PVT. LTD. versus INCOME TAX OFFICER

    (2014) TaxCorp(LJ) 2740 (HC-DELHI)

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