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2020 (5) TMI 694
Liquidation of the Corporate Debtor - Section 33 (2) of the IBC, 2016 - HELD THAT:- Taking into consideration the provisions of Section 33 of IBC,2016 and in the absence of any opposition to the Application from the Promoters of the Corporate Debtor and also guided by the decision of the Hon’ble Supreme Court in the matter of Mr. K. Sasidharan -Vs-- Indian Overseas Bank [2019 (2) TMI 1043 - SUPREME COURT], this Tribunal orders for the liquidation of the Corporate Debtor.
Mr. K.C.Senthilkumar is appointed as the Liquidator of the Corporate Debtor to carry out the liquidation process subject to the terms of the directions imposed - application allowed.
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2020 (5) TMI 693
Penalty u/s 271(1)(c) - Defective notice u/s 274 - non striking off the irrelevant/ inapplicable portion on the standard format - whether penalty proceedings were to be initiated for furnishing of inaccurate particulars of income or concealment of income? - HELD THAT:- AO had issued the notice u/s 274 r.w.s. 271 (1) (c) of the Act without striking off the irrelevant/ inapplicable portion on the standard format. As pointed out by the Ld. counsel, the AO can initiate penalty proceedings against the assessee once he is satisfied that there is concealment of income or furnishing of inaccurate particulars of income or both - as held in the case of CIT vs. Samson Perinchery [2017 (1) TMI 1292 - BOMBAY HIGH COURT] that concealment of income and furnishing inaccurate particulars of income carry different connotations, therefore, the order imposing penalty has to be made only on ground on which penalty proceedings have been initiated
Since the AO has issued the notice u/s 274 r.w.s. 271 of the Act in a mechanical manner without striking off the inapplicable portion of the notice printed on standard format, the impugned order passed by the Ld. CIT(A) is not sustainable in law. Hence, we find merit in the contention of the Ld. counsel - Decided in favour of assessee.
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2020 (5) TMI 692
Grant of default bail - Robbery of Gold chain - entitlement to default bail when final report has not been filed within the mandatory time limit - HELD THAT:- It has been held in Achpal v. State of Rajasthan [2018 (9) TMI 1863 - SUPREME COURT] that the provisions of the Code do not empower any one to extend the period within which the investigation must be completed. If on the expiry of the period aforesaid mentioned, the accused applies for bail and is ready to furnish sureties, an indefeasible right would accrue in his favour - The Hon'ble Supreme Court taking note of the extraordinary situation obtaining in the country has ordered as mentioned above that the period of limitation shall stand extended until further orders. This was to obviate the difficulties faced by the litigants and to ensure that they and their lawyers do not have to come physically to file in the respective Courts and Tribunals. The Hon'ble Supreme Court has not mentioned that police investigations would also be covered by the said order.
The limitation barrier prescribed for institution of suits is impregnable and cannot be breached. However, Section 5 of the Limitation Act provides for extension of prescribed period in certain cases. If Section 5 of the Limitation Act is not excluded either expressly or by implication, the power to condone delay in filing the appeal or application can always be invoked. The special laws also contain special periods of limitation with or without power to condone delay - The expiry of the period results in accrual of right in favour of the accused. Even though this time limit is referred to as period of limitation, technically it is not. It is only Chapter XXXVI of Cr.Pc that deals with limitation for taking cognizance of certain offences. Even Section 167 (5) of Cr.Pc has been interpreted to mean that the magistrate shall only make a direction for stopping further investigation in a summons case if it is not concluded within the period of six months and the said period has not been extended and it does not bar the magistrate from taking cognizance based on the final report filed thereafter. Hence, Section 167 of Cr.PC cannot be construed as containing the period of limitation for filing of final reports.
Personal liberty is too precious a fundamental right. Article 21 states that no person shall be deprived of his personal liberty except according to procedure established by law - the prosecution has a right to apply for extension of time.
The petitioner is entitled to default bail - Petition allowed.
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2020 (5) TMI 691
Denial of Predominance over the statutory charge due to Government - Whether a secured creditor can claim priority for sale and payment over statutory charge holders, due under State enactment? - SARFAESI Act and the RDB Act - HELD THAT:- The SARFAESI Act and the RDB Act are Central enactments while the KVAT Act is a State enactment. The effect of inconsistency between a Central enactment and State enactment is resolved by recourse to Art. 254(1) and Art. 246 of the Constitution of India. Art. 254(1) deals with the Parliamentary supremacy in matters in which Parliament is competent to enact. Competence to enact a law is as specified under Art. 246. Supremacy of Parliament will be maintained irrespective of any conflict between matters in which both Centre and the State can enact on a subject matter - as per Article 254, the Central law will prevail, subject of course to the provisions in Art. 254(2). If a provision of law contained in the Concurrent list is made by the State legislature and receives assent of the President, then such a State enactment will prevail. The intention of the Constitution makers is evident that there must be uniform application of laws throughout the territory of India and in the event of any inconsistency between the Central law and the State law, the former alone shall be operative.
When the inconsistency between the provisions of a Central Act and a State Act is of such a nature that they come into direct collision with each other, and it is impossible to comply with one without disobeying the other, a clear case of repugnancy arises. Repugnancy may also arise between the two enactments, even though obedience to each of them is possible without disobeying the other, if the competent Legislature of superior efficacy, expressly or impliedly evinces by the legislation, a clear intention to cover the whole field - it can safely be concluded that the provisions of SARFAESI Act and RDB Act (as amended) containing provisions commencing with non-obstante clauses and giving specific priority to secured creditors even over the taxes due from the Governments, will prevail over the KVAT Act.
The sale carried out either under the SARFAESI Act or under the RDB Act takes precedence over the statutory charges due to the Government created under KVAT Act or under other State Enactments after the Amendment Act of 2016. A secured creditor in whose favour a security interest has been created thus has priority in sale and payment over all other statutory charge holders.
The 2nd respondent Sub Registrar, Kottarakkara is directed to register the original of Annexure-A4 sale certificate as and when the same is presented for registration - Application allowed.
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2020 (5) TMI 690
Addition relating to suppression of fee receipts of Management/NRI quota - addition based on document seized from the residence of the Chairman Shri P L Nanjundaswamy - contention of the assessee is that it is not aware of existence of any such document and accordingly it has disowned the same - HELD THAT:- In the instant case, the AO’s case is that the assessee has suppressed the fees received by it for giving admission under management/NRI quota. AO did not accept the explanations of the assessee in this regard. However, he did not bring any material on record to show that the assessee, indeed, collected fees over and above that were accounted for in the books of account. AO did not reveal/discuss the result of enquiry conducted by him by issuing notices u/s 133(6) of the Act. Hence the assessee has contended that the assessing officer did not receive any adverse reply from the students. Even though the AO has observed that huge cash was seized during the course of search, yet it was shown by the assessee that all those cash are accounted for in the books of accounts.
As noticed that the Ld CIT(A) has agreed with the inferences drawn by the AO. The discussions made in the preceding paragraph would also show that the assessing officer has only drawn certain inferences on surmises and conjectures. Hence we are unable to sustain the view taken by Ld CIT(A) on this issue. Accordingly, we set aside the order passed by Ld CIT(A) on this issue and direct the AO to delete the addition made in AY 2009-10 towards suppression of fee on MBBS Management Quota. - Decided in favour of assessee.
Addition towards suppression of fees under P.G admission - suppression of fee receipts of Post graduate seats - AO has made this addition on the basis of certain documents pertaining to the AY 2009-10 and 2014-15 - HELD THAT:- AO did not conduct any independent enquiry either with the students or their parents or with any other person related to those students in order to find out the truth. He also not brought any material on record to show that the explanations given by the assessee were not correct. Hence, we are of the view that the assessing officer should not have drawn presumptions without conducting proper enquiry. The assessee has stated that the fee is not fixed uniformly for management quota seats and the same is finalized by the chairman on case to case basis. It is also undisputed fact that the revenue did not unearth any material with regard to the remaining four seats. Under these set of facts, it may not be correct on the part of the AO to presume that the assessee would have collected more fees in respect of remaining four seats.
Though the AO has taken support of the diary relating to AY 2014-15 to entertain presumption that the assessee has been suppressing the fees, in our considered view, it may not be right to presume that the circumstances prevailing in one year existed in other years also. In any case, the assessee was not given opportunity to examine Mr. Manjunatha, who had maintained the diary. Accordingly, we are of the view that the ld CIT(A) was not justified in confirming this addition.Decision rendered in the case of Balaji Educational & Charitable Public Trust [2015 (4) TMI 342 - MADRAS HIGH COURT] would apply to this addition also. Accordingly, we set aside the order passed by Ld CIT(A) on this issue in AY 2009-10 and direct the AO to delete the addition.- Decided in favour of assessee.
Addition relating to suppression of fees of COMED-K candidates - As noticed earlier that 40% of the MBBS seats are filled up on the basis of common entrance test conducted by the association or body of professional colleges - CIT(A) deleted this addition and hence the revenue has filed this appeal - HELD THAT:- There is no dispute that the fee structure under this category is lower than the fees applicable for management quota. In this kind of situation, if any student has qualified under entrance examination conducted for COMED-K category and admission is also made out of the rank list of that examination, then no one will agree to pay higher fees than that prescribed for COMED-K category. If anybody agrees to pay, the same would be against human probabilities. If the assessee had demanded higher fees, then the concerned student had right to lodge a complaint with the State Government, as it violative of the consensual agreement entered between the Association and Government. AO has not shown that any such complaint was received against the assessee by the State Government or Association.
Assessee has explained that the letters issued to the prospective students, which were seized by the revenue, pertained to management quota seats. The revenue has seized letters issued to four students, out of which only two students have joined under COMED-K category. The assessee has furnished confirmation letters obtained from those two students confirming that they have paid only prescribed fees. We notice that the AO did not disprove the contents of the confirmation letters. In any case, those letters pertained to AY 2014-15 and not to the assessment year 2009-10, which is under consideration.
AO has not conducted any enquiry with any of the students or their parents or any other person to support the inference drawn by him that the fees applicable to management quota seats were collected from the students admitted under cancelled seats of COMED-K category. The detailed discussions made by the Ld CIT(A) would show that the assessee has answered all the queries raised by the AO in this regard and none of the said explanations have been proved to be wrong by the assessing officer. No infirmity in the decision taken by Ld CIT(A) on this issue and accordingly confirm the deletion. - Decided against revenue.
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2020 (5) TMI 689
Maintainability of application - Jurisdiction to entertain application - Approval of Resolution Plan - Section 31 of the Insolvency and Bankruptcy Code, 2016 - refund of forfeiture of the Bid Bond Guarantee - HELD THAT:- Issue notice.
Until further orders, the parties are directed to maintain status quo, as on today, with respect to liquidation. Reply, if any, be filed within four weeks.
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2020 (5) TMI 688
Composite Scheme of Amalgamation and Plan of Merger (Scheme) - sections 230 to 232 read with section 234 and other applicable provisions of the Companies Act, 2013 - HELD THAT:- Various directions regarding holding, convening and dispensation of various meetings issued - directions regarding issuance of various notices issued.
The scheme is approved - application allowed.
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2020 (5) TMI 687
Levy of GST - demand of tax at 18% - monthly licence fee collected from the petitioner for the work of contract of maintenance of toilets in addition to the monthly licence fee - N/N. 12/2017-Central Tax (Rate), dated 28.06.2017 and G.O.Ms.No.588, dated 12.12.2017 issued by Revenue (Commercial Taxes-II) Department, Government of Andhra Pradesh - HELD THAT:- The work contract of maintenance of toilet blocks at the 4th respondent Depot awarded to the petitioner comes within the purview of the exemption granted by the Central Government as well as the State Government. The said notification and the G.O. prevail over the terms and conditions of the licence deed. On perusal of the impugned proceedings dated 28.12.2019, this court found that the 3rd respondent issued the said proceedings only based on the licence deed and without reference to the Notification and the G.O. It is well settled that the clauses and the terms in the agreement or licence deed, which are contrary to the provisions of law and the notifications issued by the Governments, could not bind the parties to the agreement. Therefore, the action of the respondents in insisting payment of GST as per clause 47 of the licence deed is found to be illegal, arbitrary and contrary to the Notification and the G.O.
The 3rd respondent being the class-I officer of the respondent Corporation is under obligation to consider the purport of the notifications and the orders issued by the competent authority granting exemptions from payment of GST for the services rendered by the petitioner, as he is supported by well competent legal department and legal advisors, instead of driving the petitioner to this court.
The writ petition is allowed by setting aside the proceedings, with costs of ₹ 5,000/- payable by the 3rd respondent to the Andhra Pradesh State Legal Services Authority, within a period of four weeks from the date of receipt of a copy of the order.
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2020 (5) TMI 686
Levy of GST in addition to licence fee - business for the work of contract of maintenance of toilets in the Bus Station, Guntur, including all offices of the Bus Station on a monthly licence fee - HELD THAT:- The petitioner was entrusted with the work contract of maintenance of toilets in the Bus Station, Guntur by licence deed dated 19.02.2017 from 19.02.2017 to 18.02.2019 extendable to one year subject to satisfactory performance of the contract by the petitioner on a monthly enhanced licence fee payable to the Corporation by collecting user charges from the toilet users.
As per clause 43 of the licence deed, the petitioner is liable to pay 18% towards GST (9% of Central GST and 9% of State GST) in addition to the licence fee. But, as per Notification No.12/2017- Central Tax (Rate), dated 28-06-2017 issued by the Central Government and G.O.Ms.No.588, Revenue (Commercial Taxes-II) Department, dated 12-12-2017 issued by the Government of Andhra Pradesh - On perusal of the impugned proceedings dated 19.01.2019, this court found that the 3rd respondent issued the said proceedings only based on the licence deed and without reference to the Notification and the G.O. It is well settled that any clauses and the terms and conditions in the agreement or licence deed, which are contrary to the provisions of law and the notifications issued by the Governments, could not bind the parties to the agreement. Therefore, the action of the respondents in insisting payment of GST as per clause 43 of the licence deed is found to be illegal, arbitrary and contrary to the Notification and the G.O.
The 3rd respondent being the class-I officer of the respondent Corporation is under obligation to consider the purport of the notifications and the orders issued by the competent authority granting exemptions from payment of GST by the petitioner as he is supported by well competent legal department and legal advisors, instead of driving the petitioner to this court - the impugned proceedings issued by the 3rd respondent are liable to be set aside - Petition allowed.
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2020 (5) TMI 685
Seeking admission and for fixing a date of hearing of the main Company Petition as well as for a direction in relation to publication in press to be effected and notices to be issued to the authorities concerned - Sections 230-232 of the Companies Act, 2013 - HELD THAT:- This petition on second motion filed on 30.07.2019 is coming up before us for fixing a date of hearing as well as for other consequential directions in terms of provisions of Sections 230 to 232 of Companies Act, 2013 read with Rule 16 of the Companies (Compromise, Arrangements and Amalgamation) Rules, 2016, brought into effect and on and from 15.12.2016.
The date of hearing of the Petition filed by the Petitioner for the sanction of the Scheme is fixed on 11™ June 2020 - The next date of hearing of the Petition shall be on 11th June2020 for the consideration of the approval of the Scheme as contemplated among the Petitioner Companies.
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2020 (5) TMI 684
Seeking transfer of pending petition before this Court to the file of the National Company Law Tribunal, Chennai Bench - initiation of CIRP - HELD THAT:- In the instant case, the proceeding is only at the notice stage and it is only C.P.No.21 of 1995 that has been admitted. The Official Liquidator is yet to be appointed as per the provisions of the Act. The argument of the Third respondent that once the recommendation of the BIFR has been approved by this Court what remains is only the Ministerial Act of winding up cannot be countenanced. Once the petition is received from the BIFR it is thereafter numbered as a Company Petition and the entire procedure envisaged for a winding up proceedings has to be followed to the letter. Further the creditors and contributories of the company are also to be paid their dues first as the case of the Workmen.
Reliance placed in "Jaipur Metals and Electricals Employees Organisation Vs. Jaipur Metals and Electricals Ltd [2018 (12) TMI 674 - SUPREME COURT], where it was was dealing with the order passed by the High Court of Judicature of Rajasthan refusing to transfer winding up proceedings pending before it to the National Company Law Tribunal (NCLT) and further setting aside the order dated 13.04.2018 of the NCLT admitting a creditor's petition under Section 7 of the Insolvency and Bankruptcy Code, 2016.
This Court has no other alternative but to allow the application. It is needless to state that this order does not affect the rights of the workmen granted to them in the Writ proceedings as upheld by the Hon'ble Supreme Court.
Application allowed - petition stands transferred to the file of the National Company Law Tribunal, Chennai Bench, to initiate Corporate Insolvency Resolution Process under the Insolvency and Bankruptcy Code, 2016.
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2020 (5) TMI 683
Deduction u/s 80IC - deduction denied as assessee not doing any manufacturing or processing activity but only mixing and repacking various ingredients and thus no finished product distinct from the raw material has come into existence, which may fall within the meaning of words "manufacturing, processing and production" - HELD THAT:- Similar issue decided in KHUSHBU INDUSTRIES [2016 (11) TMI 68 - ITAT LUCKNOW] claim of deduction under section 80IC is admissible. We have also noted that, as noted by the Assessing Officer, just because the assessee has used certain raw materials in the organic and inorganic chemicals, it does not mean that the product manufactured is also in the nature of organic or inorganic chemicals. There is also a categorical finding to the effect that “the products manufactured by the assessee fall under chapter 33 related to ‘essential oils, resinoids, perfumery, cosmetic or toilet preparations’ and donot fall under chapter 28 or 29 dealing with organic/ inorganic chemicals”. Nothing has been brought before us to dislodge these findings. We, therefore, see no merits in the grievances of the Assessing Officer.
Assessee is engaged in manufacturing and production of an article and therefore, the assessee shall be entitled for the deduction available u/s 80IC of the Act. We accordingly confirm the order of CIT(A) as in our opinion, no illegality or infirmity is found in the order of CIT(A). Decided in favour of assessee.
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2020 (5) TMI 682
Maintainability of application - initiation of CIRP - Corporate Debtor failed to make repayment of its dues - Financial Creditors or not - existence of debt and dispute or not - execution of the Debenture Trust Deed - HELD THAT:- The execution of the Debenture Trust Deed and allotment of the debenture to the debentures holders is not in dispute. It is also not in dispute that the Respondent defaulted in honouring the redemption on the schedule dates as per Annexure 2 of the Debenture Trust Deed. It partially redeemed debentures on 12.12.2017, which were due on 31.10.2017. It is not disputed that it failed to pay any amount due including interest subsequent to October, 2017 despite issue of notice of acceleration and recall dated 31.01.2019 - Respondent accordingly was in default in payment of a financial debt.
The Code has overriding effect over any other law or any instrument having the effect of law. The agreement between the parties as to the jurisdiction of Courts at Hyderabad cannot override express provision of the Code which provides for a specialised mechanism for Corporate Insolvency Resolution. The parties cannot decide jurisdiction of the resolution of their dispute in violation of the express provision of any statute. The contention as to lack of jurisdiction of this Authority raised by the Respondent accordingly cannot be accepted - issue answered in affirmative.
Petition admitted - moratorium declared.
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2020 (5) TMI 681
Maintainability of application - initiation of CIRP - Corporate Debtor failed to make repayment of its dues - Operational Creditors - time limitation - existence of debt and dispute or not - HELD THAT:- The Petition has been filed on 30.07.2018 for unpaid operational debt due and defaulted of INR.21,57,700.38 with interest accrued thereon at the rate of 30% per annum from the respective due date of each invoice - Date of default is 10.11.2016 as per the agreed terms of payment after 07 days and they approached to the Corporate Debtor, Honest Derivatives Private Limited for payments many a times but they found that he was not intend to pay - Application is filed within the limitation period as the date of default 10.11.2016, whereas the date of filing this petition under Section 9 of IBC is 30.07.2018.
Respondent is a Company registered under the Companies Act and it is a Corporate Debtor within the meaning of sub-section (8) of Section 3 of the 1B Code.
No pre-existing dispute before issuing of Demand Notice is observed. Defence taken by the Respondent is not tenable. The Respondent has taken defence of existing dispute prior to the issue of Demand Notice by the Petitioner on 03.02.2018 but the fact is that the Respondent has filed Suit on 26.03.2018 against the Applicant i.e. after receipt of Demand Notice inter alia seeking damages and losses suffered under the said PO by the Respondent - the Respondent also filed a Suit on 15.03.2018 against Rawalwasia an associate concern in respect of the breaches and losses suffered by the Respondent under the HSS Agreement by the Respondent beari g Civil Suit No.36 of 2018 before the Honble Civil Judge Senior Division Jalgaon at Jalgaon. Hence, it is not considered as dispute.
The other suit has been filed against the Associate Company of the Petitioner for violation of HSS agreement but it does not relate in any way to the Petitioner's claim against the Respondent. Hence, this defence is not entertained.
The application is complete and is admitted - moratorium declared.
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2020 (5) TMI 680
Seeking approval of Resolution Plan - Section 30(6) r/w Section 31 of the Insolvency and Bankruptcy Code, 2016 - HELD THAT:- There are no ground to interfere with the impugned order passed by the Tribunal. The appeal is, accordingly, dismissed.
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2020 (5) TMI 679
Permission for withdrawal of appeal - Section 12A of the ‘Insolvency and Bankruptcy Code, 2016’ - HELD THAT:- The appeal is accordingly disposed of as withdrawn with liberty to the Appellant to invoke Section 12A of the ‘I&B Code’ giving an offer which shall be considered by the ‘Committee of Creditors’ irrespective of rejection of any earlier offer.
Appeal disposed off.
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2020 (5) TMI 678
Stay petition - application was moved seeking extension of stay granted to the applicant - HELD THAT:- The last stay order which was granted to 09.03.2020 under which no conditions were imposed. The stay was extended to 60 days i.e. ending on 08.05.2020. The issue involved in the present appeal is against the transfer pricing adjustments made and the case of the applicant before us is limited to selection and application Of margins of comparables.The applicant has a prima facie case in its favour as far as granting extension of stay against the recovery of balance outstanding demand is concerned. The stay of demand can be granted to the applicant for a period exceeding 365 days as held by the Hon'ble Delhi High Court in the Case of Maruti Suzuki India Ltd. [2014 (2) TMI 1037 - DELHI HIGH COURT] and in the case of Pepsi Foods (P.) Ltd. [2015 (5) TMI 655 - DELHI HIGH COURT]
Coming to the next stand of the Ld.DR for the Revenue as to application of amended provisions Of section 254(2A) Of the Act. The said provisions have been inserted by the Finance Act, 2020 w.e.f. 01.04.2020. The present case is of extension of stay and we are Of the view that the said provisions cannot be invoked in the present stay petition of extension of stay. Accordingly, we stay the recovery of outstanding demand for a period of 180 days or till the disposal of appeal, whichever is earlier. The appeal is fixed for healing on out of turn basis 22.06.2020. Both parties are informed through this order and no separate notice of hearing shall be issued. Both the parties are directed not to take frivolous adjournment. Hence, the stay application filed by the applicant stand allowed.
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2020 (5) TMI 677
Authorization for important clearance of secondhand digital multifunction print and copying machines - HELD THAT:- There are no reason to interfere with the impugned interim order passed by the High Court, more particularly, taking note that certain special leave petitions assailing the same impugned order have already been dismissed by this Court on 17.02.2020. Accordingly, the instant special leave petitions are dismissed.
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2020 (5) TMI 676
Seeking permission for withdrawal of SLP - liberty also sought to file a regular bail application before the learned Single Judge - HELD THAT:- The special leave petition is dismissed as withdrawn. Learned senior counsel for the petitioner is at liberty to file a regular bail application which may be decided in accordance with law expeditiously.
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2020 (5) TMI 675
Validity of the re-assessment proceedings - protective assessment done - assessee had not offered any capital gain to tax on 50% of right of land transferred to the developer and has offered capital gain to tax only for the flats sold during the relevant AY i.e. AY 2007-08 - HELD THAT:- AO has made the protective assessment in order to save the interest of the revenue if it fails before the higher forums. The Hon’ble Bombay High Court in the case of DHFL Venture Capital Fund [2013 (6) TMI 575 - BOMBAY HIGH COURT] has held that it would be impermissible for the AO to make protective assessment by reopening an assessment on the ground that a contingency may arise in future resulting in escapement of income. In this case also, the AO had reopened the assessment on the hypothesis that if the Tribunal were to grant relief to the assessee, it would escape assessment.
Thus, it can be seen that an assessment completed u/s. 143(3) of the Act, cannot be reopened on a presumption that it may escape assessment in future, if the revenue failed in its litigation before the Hon’ble High Court. Thus, we are satisfied that the reassessment proceedings initiated and completed on protective basis are null and void. - Decided in favour of assessee.
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