In a landmark ruling, the ITAT Delhi allowed deduction of sales tax penalty as business expenditure, carving out an exception to the general prohibition. The Tribunal held that where an assessee, under compulsion of prevailing authoritative interpretation (here, sales tax department’s consistent stance), collects tax later held invalid, any resultant penalty falls on them as a trader with no alternative. This ‘no-alternative’ test distinguishes involuntary compliance from voluntary breaches, making the expenditure deductible under section 37(1). The decision underscores that deductibility hinges on whether the liability arose intrinsically from business operations under contemporaneous legal understanding, not hindsight.

In this landmark ITAT ruling, the Tribunal upheld the tax authority’s position that service tax collected by non-resident shipping companies must be included in gross receipts for computing presumptive income under section 44B of the Income Tax Act. The decision clarifies that statutory levies like service tax, though collected as an agent of the government, constitute trading receipts when incidental to core business operations. The Tribunal rejected the ‘profit element’ argument, emphasizing that section 44B’s explanatory language includes amounts without profit character. However, the appeal was partly allowed as the Tribunal quashed interest levied under section 234B, following binding precedent that no interest can be charged when tax was deductible at source. This ruling significantly impacts international shipping companies operating in Indian waters, reinforcing broad interpretation of ‘aggregate amount’ under presumptive taxation regimes.

In this landmark Supreme Court judgment, the Revenue successfully appealed against the High Court’s decision. The apex court, applying the doctrine of precedent, held that the case was squarely covered by its earlier ruling in Ganesh Dass Sreeram vs. ITO. Consequently, the Court allowed the appeal, overturned the High Court’s judgment, and answered the referred questions affirmatively in favor of the Revenue, establishing consistency in judicial interpretation of the relevant Income Tax Act provisions.

In this landmark Supreme Court ruling, the bench led by Chief Justice S.H. Kapadia and Justice Madan B. Lokur decisively resolved the Department’s appeals regarding Section 80IA deductions by applying the binding precedent established in Liberty India. The Court’s streamlined approach demonstrates the critical importance of precedent in tax litigation, providing certainty and efficiency in judicial administration while reinforcing the principle that identical legal issues need not be re-litigated.

The Supreme Court dismissed a special leave petition filed by the Principal Commissioner of Income Tax, Ajmer against M/s Ajmer Vidyut Vitran Nigam Ltd. The dismissal was based on the Court’s previous order in Civil Appeal No.151 of 2015 and connected matters, indicating that the legal questions involved were already settled. This reflects the Court’s approach of maintaining consistency in tax litigation and avoiding repetitive adjudication of similar issues.

In this landmark judgment, the Supreme Court of India, comprising Chief Justice S. H. Kapadia and Justice Madan B. Lokur, definitively resolved a critical tax dispute under Section 80HHC of the Income Tax Act 1961 for Assessment Year 1994-1995. The core legal issue centered on whether leasing rights constitute ‘goods’ and their transfer qualifies as ‘sale’ for export profit deductions. Relying on the binding precedent of Commissioner of Income-Tax vs. B. Suresh (2009), the Court affirmed the assessee’s position, reinforcing judicial consistency in tax interpretation and providing clarity for businesses engaged in leasing exports. This decision underscores the Court’s role in harmonizing tax law with commercial realities, ensuring predictable outcomes for taxpayers and the Department alike.

In this landmark Supreme Court judgment, the Revenue Department successfully appealed against the taxpayer’s claim for deductions under Section 80IA of the Income Tax Act 1961. The Court decisively ruled in favor of the Revenue by applying the binding precedent established in Liberty India vs. CIT (2009) 317 ITR 218, confirming that the legal interpretation of Section 80IA deductions was already settled. This judgment reinforces the importance of precedent in Indian tax jurisprudence and provides clarity for taxpayers and practitioners regarding the application of Section 80IA deductions in similar circumstances.

In this landmark Supreme Court judgment, the Department challenged the allowance of Section 80IA deductions for texturing and twisting of polyester yarn, claiming it constituted ‘manufacture.’ The Court swiftly dismissed the appeals by applying the doctrine of precedent, relying on its 2010 decision in Emptee Poly-Yarn which had conclusively settled that such processes do not amount to manufacture under Section 80IA. This judgment reinforces judicial consistency and finality in tax interpretation, providing certainty for textile industry taxpayers regarding eligibility for industrial deduction benefits.