Showing posts with label concealment. Show all posts
Showing posts with label concealment. Show all posts

Monday, 9 June 2014

Gist of recent important tax caselaws



Below are the recent important tax caselaws related to Income tax, Service tax, Excise in brief. The citation is made available for your benefit :
INCOME TAX


SECTION 145
METHOD OF ACCOUNTING - ADDITIONS TO INCOME
Emails as sale evidence : Where Assessing Officer made addition to assessee's income in respect of additional sale consideration received on sale of land merely on basis of an e-mail recovered during course of search action at premises of another person and there was no independent material available supporting such an addition, Tribunal was justified in deleting addition so made - Commissioner of Income-tax v. Alpha Impex (P.) Ltd. (2014) 45 taxmann.com 205 (Bombay)
 
 
SECTION 271(1)(c)
PENALTY - FOR CONCEALMENT OF INCOME
Agreed additions : In absence of concrete material on record indicating that assessee had concealed particulars of income, Assessing Officer could not pass penalty order merely on basis of declaration of undisclosed income by a partner of assessee-firm in course of search proceedings - Commissioner of Income-tax, Dhanbad v. Ganesh Trading Company (2014) 45 taxmann.com 209 (Jharkhand)
 
 
 
SERVICE TAX
SECTION 73
RECOVERY - OF DUTY OR TAX NOT LEVIED/PAID OR SHORT-LEVIED/PAID OR ERRONEOUSLY REFUNDED
Where Revenue was itself insisting on payment of service tax under reverse charge on services received from abroad prior to 18-4-2006, payment of tax and taking of credit by assessee could not be said to be against law - Ericsson India (P.) Ltd. v. Commissioner of Central Excise (Adjudication), New Delhi (2014) 45 taxmann.com 238 (New Delhi - CESTAT)

SECTION 80
PENALTY - NOT TO BE IMPOSED IN CERTAIN CASES
In view of finding of fact that there was no mala fide intent of assessee in not depositing service tax in time, penalty could be waived under section 80 - Commissioner of Central Excise v. Muniruddin (2014) 45 taxmann.com 218 (Allahabad)
 


Friday, 21 March 2014

Gist of recent important tax judgements



Below are the recent important tax caselaws related to Income tax, Service tax, Excise in brief. The citation is made available for your benefit :

INCOME TAX
 Date of SetUp
SECTION 28(i)
BUSINESS - COMMENCEMENT OF /CARRYING ON OF
Setting up of business : Where assessee-company was incorporated on 4-8-2005 to carry on real estate business and it had taken loan for business on 16-5-2006 and later on 31-5-2006 it had entered into a memorandum of understanding with third parties in respect of a project and subsequently joint venture agreement was executed between assessee and third parties on 5-7-2006, Assessing Officer was wrong in concluding that business of assessee was set up on 5-7-2006 - Commissioner of Income-tax , Delhi –I v. Arcane Developers (P.) Ltd. (2014) 42 taxmann.com 10 (Delhi)
 
 
SECTION 271(1)(C)
PENALTY - FOR CONCEALMENT OF INCOME
Revise return, effect of filing of : Where assessee offered additional income after search operation unearthing substantial undisclosed income for earlier years, concealment penalty was to be imposed upon assessee and waiver of penalty could not be granted - Commissioner of Income-tax (Central), Ludhiana v. Bansal Abushan Bhandar (2014) 42 taxmann.com 9 (Punjab & Haryana)
 
 
 
SERVICE TAX
SECTION 65(102)
STORAGE AND WAREHOUSING OF GOODS SERVICES
Supply of vessels on charter hire basis for offshore operations involving transport of crude oil and incidental storage thereof is prima facie 'Supply of Tangible Goods for Use Service'; and not Storage and Warehousing of Goods Service - Shipping Corporation of India Ltd. v. Commissioner of Central Excise & Service Tax (LTU), Mumbai (2014) 42 taxmann.com 91 (Mumbai - CESTAT)
 
 
 
 

Thursday, 5 December 2013

Sec. 271(1)(c) Penalty: Law On Discharge Of Onus In View Of SC Verdict In MAK Data Explained

CIT vs. M/s. Gem Granites (Karnataka) (Madras High Court)

 

S. 271(1)(c) penalty cannot be levied if the assessee discharges the primary burden by a cogent explanation and the AO is unable to rebut it. MAK Data (SC) explained

Pursuant to a search conducted u/s 132 it was revealed that the assessee had “on-money” transactions in real estate dealings. The assessee accepted the “on-money” but claimed that it was taxable only on completion of the projects under the ‘completed contract method‘. The assessee’s claim was rejected by all the authorities including the High Court. In the s. 271(1)(c) penalty proceedings, the assessee claimed that there was a mistake in the entries regarding the sale of flats to J.B. Exports in as much as the rate at which the property was shown as sold to the said party was much higher than the rate at which the property was sold to other parties. The AO and CIT(A) rejected the claim but the Tribunal accepted it on the basis that the huge difference in the rate of sale of the flat recorded in other cases and in the case of J.B. Exports supported the assessee’s contention that there may be a mistake in recording the rate. It held that as the department had failed to prove concealment without any doubt, penalty could not be imposed. On appeal by the department to the High Court, HELD dismissing the appeal:
Merely because the assessment proceedings have been confirmed does not automatically mean that penalty u/s 271(1)(c) is justified. Unless the case is strictly covered by s. 271(1)(c), penalty cannot be invoked. For sustaining penalty, the bona fide explanation of the assessee must be looked at so that the contumacious conduct of the assessee for the purpose of sustaining the penalty would be taken as condition that is the main requirement u/s 271(1)(c). In Mak Data P. Ltd vs. CIT the Supreme Court held that when a difference is noticed by the AO between the reported and assessed income, the Explanation to Section 271(1) raises a presumption of concealment and the burden is on the assessee to show otherwise, by cogent and reliable evidence. When the initial onus placed by the Explanation has been discharged by the assessee, the onus shifts on the Revenue to show that the amount in question constituted undisclosed income. On facts, the onus cast upon the assessee has been discharged by giving a cogent and reliable explanation. If the department did not agree with the explanation, the onus was on the department to prove that there was concealment of particulars of income or furnishing inaccurate particulars of income. Such onus has not been discharged by the department and so the Tribunal’s finding cannot be interfered with (Dharmendra Textiles Processors 306 ITR 277 (SC) & Reliance Petroproducts 322 ITR 158 (SC) referred)

Thursday, 31 October 2013

S. 271(1)(c) Penalty: Supreme Court Explains Entire Law On Voluntary Surrender

MAK Data P. Ltd vs. CIT (Supreme Court)

Under Explanation 1 to s. 271(1)(c), voluntary disclosure of concealed income does not absolve assessee of s. 271(1)(c) penalty if the assessee fails to offer an explanation which is bona fide and proves that all the material facts have been disclosed

The assessee filed a return of income for AY 2004-05 declaring an income of Rs.16 lakhs. During the course of the assessment proceedings, the AO noticed certain documents comprising of share application forms, bank statements, blank share transfer deeds etc had been impounded in the course of s. 133A survey proceedings conducted in the case of the assessee’s. The AO sought specific information regarding the documents from the assessee. In reply to the show-cause notice, the assessee made an offer to surrender Rs.40.74 lakhs with a view to avoid litigation and buy peace and to make an amicable settlement of the dispute. The AO assessed the said sum of Rs.40.74 lakhs to tax and levied penalty u/s 271(1)(c) for concealment of income and not furnishing true particulars. This was upheld by the CIT(A) though the Tribunal reversed it on the ground that the surrender was without admitting any concealment. On appeal by the department, the High Court (87 DTR 172 (Del)) reversed the Tribunal on the ground that as there was absolutely no explanation by the assessee for the concealed income of Rs.40.74 lakhs, the first part of clause (A) of Explanation 1 to s. 271(1)(c) is attracted. On appeal by the assessee to the Supreme Court HELD dismissing the appeal:
(i) The Tribunal has not properly understood or appreciated the scope of Explanation 1 to s. 271(1)(c). The AO shall not be carried away by the plea of the assessee like “voluntary disclosure”, “buy peace”, “avoid litigation”, “amicable settlement”, etc. to explain away its conduct. The question is whether the assessee has offered any explanation for concealment of particulars of income or furnishing inaccurate particulars of income. Explanation to s. 271(1) raises a presumption of concealment, when a difference is noticed by the AO, between reported and assessed income. The burden is then on the assessee to show otherwise, by cogent and reliable evidence. When the initial onus placed by the explanation, has been discharged by him, the onus shifts on the Revenue to show that the amount in question constituted the income and not otherwise;
(ii) The assessee has only stated that he had surrendered the additional sum of Rs.40.74 lakhs with a view to avoid litigation, buy peace and to channelize the energy and resources towards productive work and to make amicable settlement with the income tax department. The statute does not recognize those types of defences under Explanation 1 to s. 271(1)(c) of the Act. It is trite law that the voluntary disclosure does not release the assessee from the mischief of penal proceedings. The law does not provide that when an assessee makes a voluntary disclosure of his concealed income, he had to be absolved from penalty;
(iii) On facts, the surrender of income is not voluntary in the sense that the offer of surrender was made in view of detection made by the AO in the search conducted in the sister concern of the assessee. In that situation, it cannot be said that the surrender of income was voluntary. AO during the course of assessment proceedings has noticed that certain documents comprising of share application forms, bank statements etc have been impounded in the course of survey proceedings u/s 133A conducted in the case of the assessee’s sister concern. The survey was conducted more than 10 months before the assessee filed its return of income. Had it been the intention of the assessee to make full and true disclosure of its income, it would have filed the return declaring an income inclusive of the amount which was surrendered later during the course of the assessment proceedings. Consequently, it is clear that the assessee had no intention to declare its true income;
(iv) It is the statutory duty of the assessee to record all its transactions in the books of account, to explain the source of payments made by it and to declare its true income in the return of income filed by it from year to year. The AO has recorded a categorical finding that he was satisfied that the assessee had concealed true particulars of income and is liable for penalty proceedings u/s 271 read with s. 274 of the Act;
(v) The AO has to satisfy himself whether penalty proceedings be initiated or not during the course of the assessment proceedings. He is not required to record his satisfaction in a particular manner or reduce it into writing. The scope of s. 271(1)(c) has also been elaborately discussed by the Supreme Court in UOI vs. Dharmendra Textile Processors 306 ITR 277 (SC) and CIT vs. Atul Mohan Bindal 317 ITR 1 (SC). The principle laid down by this Court has been correctly followed by the Revenue and there is no illegality in the department initiating penalty proceedings in the instant case.
Contrast with Suresh Chandra Mittal 241 ITR 124 (MP) (affirmed in 251 ITR 9 (SC) that an offer to “buy peace” may be bona fide.