Wednesday, April 30, 2014

[aaykarbhavan] SC : Dismisses SLP; Upholds penalty on income disclosed pursuant to other person’s search



April 30 2014
​SC dismisses assessee's SLP against Delhi HC judgement; HC had upheld levy of concealment penalty where assessee offered to tax undisclosed income pursuant to search in another assessee's case
 
Regards
Prarthana Jalan


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[aaykarbhavan] SC : Denies loss carry forward to amalgamating co-operative societies absent specific IT-Act provisions



May 01 2014
SC upholds Rajasthan HC's judgment denying benefit of set off of accumulated losses of amalgamating co-operative societies against profits of amalgamated co-operative society

Courtesy: tax sutra
 
Regards
Prarthana Jalan


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[aaykarbhavan] I-T - Whether quashing of proceedings by ITAT for faulty service of notice under Ss 148, 143(2) & 142(1) amounts to allowing assessee to go scot-free even if he is liable to pay capital gains tax - YES: HC



CHANDIGARH, MAY 01, 2014: THE issues before the Bench are - Whether quashing of proceedings by the Tribunal for faulty service of notice under Ss 148, 143(2) & 142(1) amounts to allowing assessee to go scot-free even if he is liable to pay capital gains tax on compensation received for statutory acquisition of his land; Whether merely because there is an error in service of notice on the assessee, the statutory liability to pay tax on capital gains gets extinguished and Whether assessee is to be assessed at the place of its agent or the place where his land was acquired. And the Bench allows the Revenue's appeal.
The assessee Jasbir Singh received compensation amounting to Rs.1,04,54,474/- against compulsory acquisition of his land situated at village Mansoorwal Dona, District Kapurthala. The assessee had not furnished his return of income. Finding it to be a case of income having escaped assessment for the assessment year 1999-2000 by reason of failure on the part of the assessee to make a return under Section 139 of the Act, after recording reasons and obtaining necessary approval, notice under Section 148 of the Act was served on the assessee on 21.3.2006. He did not furnish his return even then. Thereafter, notice under Section 142(1) was issued along with a questionnaire. The assessee neither attended the office of the named Income Tax authority in the notice nor filed return nor made compliance of the said notice. Even on information made available, the Assessing Officer could not get current residential address of the assessee. The concerned Inspector of the revenue found that it was not possible to effect service in ordinary manner and consequently, service of the notice was effected under Section 142(1) of the Act through affixation on the last known address of the assessee. Since after acquisition of the whole land of village Mansoorwal Dona by PUDA, it had been converted into a residential colony and as such, notice was affixed on the Dharamshala of the village. None appeared on behalf of the assessee. Accordingly, the AO proceeded to frame assessment in terms of Section 144 of the Act i.e. calculating the quantum of long term capital gain for the assessment year 1999-2000 at Rs.1,00,09,746/-. As the assessee had concealed this entire income, penalty notice under Section 271-C of the Act was also issued separately for the concealment of this income on account of long term capital gains arising from compulsory acquisition of land by PUDA.
Assessee filed a petition u/s 264. The plea of the assessee was that statutory notice had not been served upon him and affixture of notice somewhere in village, where the assessee neither was residing nor was working for gain and had only agriculture land which had been acquired, was of no legal value. It was pleaded that his address was available with PUDA, Jalandhar and had the AO made some genuine efforts, his address could have been obtained from his bank account or from the office of Land Acquisition Collector, PUDA, Jalandhar and from the Income Tax Department itself where the assessee was allegedly assessed for the assessment year 1999-2000. It was elaborated that the assessment proceedings for the year 1999-2000 had already been finalised by the revenue through his power of attorney Jarnail Singh. Consequently, the CIT accepting version of the assessee had set aside order of the AO, wherein directions were issued for framing assessment afresh after allowing adequate opportunity to the assessee of being heard. Directions were also issued to the AO to ensure that contentions of the assessee were judiciously dealt with. Pursuant to this order, proceedings of assessment were started afresh. During that proceedings, it was noticed that the assessee had filed the return of income for the assessment year 1999-2000 with the Income Tax Officer, Ward-VI, Jalandhar mentioning the address as c/o Shri Jarnail Singh, resident of village Dheena, District Jalandhar Cantt. The AO noticed that the return filed by the assessee on 21.8.2000 without enclosing the power of attorney in favour of Jarnail Singh and with incorrect address, was an invalid return. The verification had also been found to be improper and thus return was invalidated on that account as well.
It was further noticed that the ITO, Jalandhar, had dropped the proceedings under Section 147 of the Act for want of jurisdiction, making a noting that jurisdiction was territorial and would not depend upon address of the power of attorney holder of the assessee. In short, it was felt that merely because power of attorney holder of the assessee was a resident of Jalandhar, there would not be jurisdiction of Jalandhar but would remain with the Income Tax Officer, Kapurthala. In this backdrop, the Income Tax Officer, Kapurthala had held that the jurisdiction over the case of the assessee was rightly vested with it. Making calculations and taking into account quantum of compensation received as Rs.1,04,54,474/-, long term capital gain was computed at Rs.26,50,340/-. Penalty proceedings under Section 271(1)(c) of the Act were also initiated separately for concealment of income. This order was challenged in appeal by the assessee; it was dismissed.
On appeal, the Tribunal accepted the version of the assessee by holding that notices should have been served on the agent of the assessee Jarnail Singh, power of attorney, and notices issued by the Income Tax Officer, Kapurthala-I, under Sections 148 as also 143(2) of the Act were bad in law and the assessment made thereunder was liable to be quashed. Accepting version of the assessee, assessments were quashed.
The plea of the Revenue was that when the Tribunal had accepted the claim of the assessee that notices issued by the Income Tax Officer, Kapurthala under Section 147 as also under Section 143(2) of the Act had neither been served on the assessee nor on his agent Jarnail Singh and thus, were of no legal significance, the assessee should not have been just let off. It was contended that when liability of the assessee to pay tax on capital gains was undisputed, he should have been brought back within the ambit and scope of law to discharge his liability.
Having heard the parties, the HC held that,
++ there is force in contention of the revenue that once service of notice under Section 148, 143(2) and 142(1) of the Act was held to be bad observing that the assessee was no more residing at the last known address and was accessible only through his attorney Jarnail Singh, it was incumbent on the Tribunal not to quash the whole proceedings as it amounted to leaving the assessee go scot-free, though he is liable to pay tax on the capital gains. It is nowhere denied that compensation for compulsory acquisition of the land was received by the assessee. As such, he cannot deny his liability to pay long term capital gain tax. Merely because there was some error in service of notices on the assessee, statutory liability of the assessee to pay tax on capital gain was not over. Because of procedural lapses, the assessee should not be a gainer and that too by default to escape his liability. Sequelly, order of the Tribunal also lacks merit;
++ looking from another angle, default made by the revenue in compliance with the procedure in place for service of the assessee ipsofacto, is not a circumstance to let the assessee go scot free from the taxation regime when his liability of payment of capital gain tax is not questioned. When the proceedings had been started by the Income Tax Officer, Kapurthala-I, Kapurthala but the same were found to be defective on technical and procedural grounds of service of the assessee, liability of payment and capital gains tax which had accrued against the assessee, would not be lost sight of and forgotten, as has been projected by the assessee;
++ it is, thus, ordered that the Income Tax Officer, Kapurthala-I, Kapurthala would start the proceedings afresh after seeking appearance of the assessee either in person or through his power of attorney and would decide the matter afresh from the stage of issuance of notice to the assessee;
++ since the land is located at village Mansoorwal Dona, District Kapurthala and the proceedings are not required to be conducted at the place of residence of power of attorney of the assessee and, in fact, the assessment proceedings are to continue at District Kapurthala where the land acquired is situated, the time spent in conducting the proceedings would be duly considered by the authorities if any question with regard to limitation at any stage arises;
++ all the substantial questions of law enumerated in earlier portion of the judgment to the extent already discussed are answered in favour of the revenue. By setting aside the impugned orders, the appeals, consequently, are allowed in favour of the revenue
 
Regards
Prarthana Jalan


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[aaykarbhavan] Sales commission paid to NR agent for services rendered outside India wasn't taxable in India; no withholding of tax




 

Sales commission paid to NR agent for services rendered outside India wasn't taxable in India; no withholding of tax

May 1, 2014[2014] 44 taxmann.com 173 (Hyderabad - Trib.)
IT/ILT : Where assessee-company made payment of sales commission to a foreign party by direct remittance for services rendered outside India, amount in question not being chargeable to tax in India, assessee was not required to deduct tax at source while making said payments
IT/ILT : Where in support of claim of deduction for sales commission paid to foreign party, assessee brought on record commission bills which clearly substantiated services rendered by foreign party, claim in question could not be rejected taking a view that transaction in question was sham
Regards
Prarthana Jalan


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[aaykarbhavan] Case remanded for de novo assessment as rental value of property wasn't determined as per direction given by CIT




 

Case remanded for de novo assessment as rental value of property wasn't determined as per direction given by CIT

May 1, 2014[2014] 44 taxmann.com 207 (Mumbai - Trib.)
IT: Where while making de novo assessment, Assessing Officer relied upon decision of co-ordinate bench of Tribunal but failed to take into consideration directions given by Commissioner for making necessary enquiries for determining fair rental value of property, matter was to be restored to file of Assessing Officer for de novo assessment in accordance with law
Regards
Prarthana Jalan


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[aaykarbhavan] CBDT Announces Ambitious National Judicial Reference System Project



Dear Subscriber,

CBDT Announces Ambitious National Judicial Reference System Project

The CBDT has announced the setting up of a "National Judicial Reference System" (NJRS).

The NJRS comprises of two components, the "Appeals repository and Management System" and the "Judicial Research and Reference System".

The Appeals repository is a database of all appeals pending in the ITAT, High Court and Supreme Court. The system will enable the status of the appeals to be tracked with an alert system. The big advantage of this database is that the entire litigation history of a tax payer will be available at the press of a button.

The Judicial Research and Reference System is a database of all decisions of the ITAT, High Courts & the Supreme Court. The cases will be indexed, searchable and cross-linked. The database will also have the relevant statutory enactments, circulars etc.

There are several other interesting aspects of the NJRS which you can read in the CBDT's letter dated 29.04.2014. From the detailed description of the NJRS, it is clear that it will be a mammoth exercise, requiring the active co-operation of a number of agencies, including the judicial bodies.

It is expected that the NJRS will go-live by November/ December 2014. We wish the CBDT good luck for timely and proper implementation of the NJRS.


Regards,

 

Editor,

 

itatonline.org

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Latest:

JM Financial Limited vs. ACIT (ITAT Mumbai)


No s. 14A/ Rule 8D disallowance for investment in shares of subsidiaries & Joint Ventures



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[aaykarbhavan] Business Standard









Shortly you will hear the news of Two/ three  Another Big 4 in lime light .




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[aaykarbhavan] Business standard update



Sebi may act on PwC's MCX audit


JAYSHREE PYASI

Mumbai, 30 April

The Securities and Exchange Board of India ( Sebi) will soon direct the BSE to independently check for violations of listing agreement norms at Multi Commodity Exchange ( MCX), following PricewaterhouseCoopers' adverse findings, said sources.

The capital market watchdog is also likely to approach the Union ministry of corporate affairs to probe allegations of breach of various clauses in the Companies Act, they said.

Separately, the commodity markets regulator, the Forward Markets Commission, on Wednesday sent the PwC audit report to MCA and the Enforcement Directorate ( ED). The ED is going to examine allegation of money laundering at MCX, sources said.

The special audit report by PwC, a summary of which was made public on Tuesday, has highlighted serious corporate governance lapses and non- compliance with regulations. For instance, the audit revealed MCX had only disclosed names of 235 related party entities, while PwC's background checks revealed at least 670 more known or related parties.

Also, the PwC audit summary noted payouts to trading members or related parities worth millions " without adequate substantiation".

BSE will have to verify whether any of the PwC findings breach any listing agreement clauses. The latter agreement is a contract between a stock exchange and a listed company. It comprises a little more than 50 clauses — on corporate governance and information- based disclosures such as filing of results, shareholding data and related party deals — which listed companies have to follow.

Failure to disclose related party business dealings is a violation of Clause 32 of the listing agreement.

MCX is the country's only listed commodity bourse. It is listed solely on the BSE; it also trades on the National Stock Exchange, under the permitted to trade category.

At present, ensuring compliance with the listing agreement has to be done by the exchanges. Typically, they order suspension of trading in companies for repeated violations of the agreement.

Violators also face a penalty of up to 25 crore under the Securities Contracts Regulation Act. " Sebi will not like to undermine the authority of BSE and will want the exchange to verify facts before taking any action on the alleged violations," said a person in the know.

Corporate governance experts said the role of independent directors and the audit committee at MCX can be questioned, given the adverse findings in the PwC audit. Shares of MCX on Wednesday ended at 533.55, down 40.55, or 7.1 per cent.

|Sebi might ask BSE to probe violation of listing norms at MCX |Regulator might also approach MCA to check for breaches in the Companies Act |PwC report has noted payouts to related parties |Failure to disclose related party business dealings is a violation of Clause 32 of the listing agreement |Listed entity violating listing agreement norms faces suspension in trading, penalty

Regulator likely to write to BSE, corporate affairs ministry on alleged violations of listing norms

 

 


--
 
CS A Rengarajan
9381011200

CS Benevolent Fund is a collective effort towards extending the much needed financial support to the community of Company Secretaries in times of distress  Let us lend support and join for noble cause.



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Investor's Eye: Stock Idea - TVS Motor Company; Update - Bharti Airtel, Federal Bank, Bajaj Corp, Greaves Cotton

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Investor's Eye

[April 30, 2014] 

Sharekhan
www.sharekhan.com

 

Summary of Contents

STOCK IDEA

 

TVS Motor Company
Recommendation: Buy
Price target: Rs123
Current market price: Rs92

 

Riding scooter demand

 

Key points

  • Riding the shift towards scooters within two-wheeler segment: TVS Motor Company Ltd (TVSL) is the fourth largest two-wheeler manufacturer in the country but has a strong presence in the scooter market as two of its largest peers (namely, Bajaj Auto and Hero MotoCorp) are mainly focused on the motorcycle segment. With a better growth in the two-wheeler segment (a 7.3% volume growth in two-wheelers against declining volumes in passenger vehicles and commercial vehicles), a better growth in scooters within the two-wheeler segment (a 23.2% volume growth in FY2014) and efforts to boost its scooter product folio (by launching Jupiter), the company is set to defend its market share in spite of the growing competition from Honda Motor Company's Indian operations. 
  • Margin improvement ahead: TVSL's historic margins have significantly lagged its peers', given its high dependence on entry-level motorcycles and mopeds. However, with an improvement in the product mix on the back of new launches and export push, we expect a margin improvement of 40-50BPS over FY2014-16. Our margin expectations are modest and the company could well surprise on the profitability front. 
  • Debt reduction to improve return ratios: In the past few years, TVSL invested substantially in its Indonesian subsidiary and other group companies which delayed the process of reducing the debt. However, with no significant investment outside the core business expected in the near future, we believe TVSL will focus more on reducing the debt level substantially (D/E ratio to drop drastically from 0.7x in FY2011 to 0.1x by FY2016) which will boost the earnings and improve the health of the balance sheet. Consequently, we also expect the company to post RoE and RoCE in excess of 20% in FY2015-16.
  • Risk: Competition in the scooter segment is intense currently, making product development and marketing more important. An inability to expand volumes in this segment would affect the revenues and profitability. Additionally, the performance of the Indonesian subsidiary remains an overhang on the consolidated financials.
  • Valuations-strong earnings and improving return ratios to support re-rating: TVSL is expected to post earnings CAGR of 22% over FY2014-16. Our margin expectations are modest and the company could positively surprise on the margin front. Further, an improvement in the balance sheet, return ratios in excess of 20% and lower investments in group companies are expected to support the valuations. Consequently, we initiate coverage on the stock with a Buy rating and a price target of Rs123, giving a 15x P/E multiple to the FY2016E earnings.

STOCK UPDATE

 

Bharti Airtel
Recommendation: Buy
Price target: Rs370
Current market price: Rs328

 

Price target revised to Rs370

 

Result highlights

  • For Q4FY2014, Bharti Airtel's consolidated top line grew by 1.4% QoQ, led by a strong performance in the Indian wireless business (a voice-volume growth of 3.8% QoQ, with a steady realisation), while the OPM expanded 60BPS on a sequential basis, resulting in a 3% Q-o-Q growth in the operating profit. The strong operating performance coupled with lower interest and tax charges resulted in a 20% sequential growth in the adjusted earnings for the quarter. 
  • The African business continued to disappoint both on the revenue as well as margin front. The dollar revenues were down 1.7% QoQ, while in rupee terms it remained flat. The soft revenues resulted in an operating deleverage leading to a margin compression of 60BPS on a Q-o-Q basis. The African business margins stood at 25.2% vs 25.8% in Q3FY2014.
  • The management sounded confident on the Indian mobile business and mentioned that the realised rates are likely to inch higher, likewise the operating leverage would result in higher margins. We believe there still exists a 30-40% gap between the realised rate and the headline tariff, which it would continue to narrow by clamping down on the discounts and the freebies, and also by increasing the headline tariffs going forward. The improving revenue performance is likely to result in an operating leverage and thereby an improvement in the consolidated margins.
  • Taking cognisance of the strong performance in the Indian business, we modeled a slight increase in the tariffs ahead, with an operational efficiency that has resulted in raising our EBITDA estimates for FY2015 and FY2016. We also incorporated the spectrum payouts, interest and amotorisation into our model, resulting in decline in our net earnings. Our revised FY2015 and FY2016 EPS are Rs13.6 and Rs15.8 respectively. The improving business environment, receding regulatory overhangs and an attractive valuation (at 5.6x its FY2016 EV/EBITDA), makes us positive on the stock. We maintain our Buy rating with a revised price target of Rs370 (valued at 6.5x its FY2016 EV/EBITDA). A potential destructive and predatory pricing strategy of Reliance Jio's entry would be the key risk to our estimate and recommendation. 

 

 

Federal Bank
Recommendation: Buy
Price target: Rs110
Current market price: Rs90

 

Steady performance, robust outlook

 

Result highlights

  • Federal Bank delivered a stable operating performance for Q4FY2014, though a one-off income (of about Rs100 crore from the interest on an income tax refund) boosted the earnings (up 24.9% YoY). The margin adjusted to the one-off income was largely stable at about 3.3%. 
  • The asset quality improved on a sequential basis driven by improved recoveries (including sales of Rs158 crore of loans to ARCs) and control on slippages. The restructured loans increased largely because of a debt recast of a state distribution company. The provision coverage ratio of 84% has increased our comfort with regards the asset quality. 
  • The financial year 2013-14 marked the consolidation of the bank's balance sheet and the bank is poised to grow stronger, with its advances estimated to grow at a CAGR of 20% over FY2014-16, driving its earnings growth at 18.5% CAGR over the same period. The asset quality remains stable and the bank is well capitalised (with tier-I CAR of 14.6%) to grow which will enhance the return ratios. We maintain our Buy rating on the stock with a price target of Rs110. Key risk: any change in the top management (as reported in the media but denied by the management) at this stage could affect the performance of the bank.

 

 

Bajaj Corp
Recommendation: Reduce
Price target: Rs180
Current market price: Rs210

 

Disappointment continues in Q4, maintain Reduce 

 

Result highlights

  • Bajaj Corp posted yet another quarter of a disappointing sales performance with the sales volume declining by about 6% resulting in flat sales of Rs184 crore in Q4FY2014. The sales volume of its flagship brand, Almond Drops Hair Oil (ADHO), declined by almost 10% (vs a volume decline of nearly 2% in Q3FY2014) mainly due to an inventory correction at the retailer and distributor levels. The inventory correction would continue if the light oil industry continues to witness moderation in offtake and affects the company's sales in the coming quarters. 
  • The price of liquid paraffin oil (one of the key inputs for Bajaj Corp) has spiked by 15% to Rs87 per kilogram in recent times. Towards the end of March this year the company took a price hike of 5% in ADHO to mitigate the impact of the higher raw material prices. However, lower sales and higher advertisement spending will take its toll on the OPM, which is expected to contract by 180BPS and stay at around 26% in FY2015.
  • Being a single brand company and catering to the premium light hair oil segment, Bajaj Corp is not expected to see any substantial improvement in its sales over the next two to three quarters. Further, a below-normal monsoon would adversely affect the company's sales, which are already under stress. We have revised downwards our earnings estimates for FY2015 and FY2016 by about 10% each to factor in the lower than expected sales volume. We maintain our Reduce rating on the stock with an unchanged price target of Rs180.

 

 

Greaves Cotton
Recommendation: Hold
Price target: Rs85
Current market price: Rs83

 

Q4 disappoints; near-term pain but expect significant improvement ahead

 

Result highlights

  • Greaves Cotton Ltd (GCL) reported another sluggish performance in Q4FY2014 both in terms of the revenues (a 12% Y-o-Y decline) and the margins. The OPM declined 210BPS YoY and the adjusted net profit (post exceptional gain) declined by 26.8% YoY to Rs28.2 crore during the quarter.
  • After a subdued performance in Q4FY2014 and for the full year FY2014, we expect a gradual recovery in the automobile volumes (particularly OEM) in FY2015. In addition, a continued effort to bring down the costs along with new launches to improve the product mix would help to expand the margins at a gradual pace. Further, any sign of a recovery in the industrial cycle would help to improve the revenue and margin performance in late of FY2015. 
  • Though the near term performance could remain weak, the expectations of a considerable improvement in the earnings (a CAGR of 15% in FY2014-16E) on the back of a revival in the automobile and industrial engine segments. Moreover, an unlevered balance-sheet and margin expansion would lead to higher return ratios. Consequently, we retain our Hold rating on the stock with the price target of Rs85.

Click here to read report: 
Investor's Eye

 

 

 

 

Sharekhan Limited, its analyst or dependant(s) of the analyst might be holding or having a position in the companies mentioned in the article.

 

 Regards,
 The Sharekhan Research Team

 

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[aaykarbhavan] Important Verdict On S. 14A/ Rule 8D + Full Bench Verdict On CBDT Low Tax Effect Circular



Dear Subscriber,

 

The following important judgements are available for download at itatonline.org.

JM Financial Limited vs. ACIT (ITAT Mumbai)


No s. 14A/ Rule 8D disallowance for investment in shares of subsidiaries & Joint Ventures

In AY 2009-10, the assessee has specifically raised a point before the AO that 97.82% of the investment is in subsidiary companies and joint venture companies and, therefore, no expenditure was incurred for maintaining the portfolio on these investments or for holding the same. The assessee has also pointed out that these investments are long term investment and no decision is required in making the investment or disinvestment on regular basis because these investments are strategic in nature in the subsidiary companies on long term basis and, therefore, no direct or indirect expenditure is incurred. The department has not disputed this fact that out of the total investment about 98% of the investments are in subsidiary companies of the assessee and, therefore, the purpose of investment is not for earning the dividend income but having control and business purpose and consideration. Therefore, prima facie the assessee has made out a case to show that no expenditure has been incurred for maintaining these long term investment in subsidiary companies. The AO has not brought out any contrary fact or material to show that the assessee has incurred any expenditure for maintaining these investments or portfolio of these investments. In Godrej & Boyce Mfg. Co it was held that s. 14A(2) does not ifso facto empower the AO to apply the method prescribed by Rule 8D straightaway without considering whether the claim made by the assessee is correct. Also, in Garware Wall Ropes it was held that a disallowance u/s 14A cannot be made if the primary object of investment is holding controlling stake in the group concern and not earning any income out of investment. Similarly, in Oriental Structural Engineers (approved by the Delhi High Court) it has been held that s. 14A disallowance cannot be made for investment in subsidiaries and SPVs out of commercial expediency


CIT vs. Shambhubhai Mahadev Ahir (Gujarat High Court – Full Bench)

CBDT's low tax effect circulars have prospective effect

Clause 11 of Instruction No. 3/2011 dated 9.2.2011 specifically states that "this instruction will apply to appeals filed on or after 9.02.2011. However, the cases where appeals have been filed before 9.02.2011 will be governed by the instructions on this subject, operative at the time when such appeal was filed." Similarly, clause 11 of instruction No. 5/2008 dated 15.5.2008 specifically provides that "this instruction will apply to appeals filed on or after 15.05.2008. However, the cases where appeals have been filed before 15.05.2008 will be governed by the instructions on this subject, operative at the time when such appeal was filed". There is, thus, no ambiguity in the instructions of either 2011 or 2008 as regards the applicability of those instructions in respect of the appeals, and, at the same time, it has also been made clear that if those appeals are not filed after the given dates mentioned in those instructions, the fate of the appeals will be governed in accordance with the instructions prevailing on the date of presentation of such appeals. In view of such clear legislative intention, we are unable to hold that even if an appeal is filed prior to 9.02.2011, the same would be barred notwithstanding the fact that at the time of filing such appeal, the same was not barred by the then instructions of the CBDT (Sureshchandra Durgaprasad Khatod reversed, Vijaya V. Kavekar (Bom), Madhukar K. Inamdar (Bom) & other judgements dissented from)


Regards,

 

Editor,

 

itatonline.org

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Latest:

Rashmikant Kundalia vs. UOI (Bombay High Court)

S. 234E: High Court grants ad-interim stay against operation of notices levying fee for failure to file TDS statement



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