Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    ManualsIncome Tax
    Whether a person is allowed HRA exemption even if he do not have the HRA component in his salary but...
    ManualsIncome Tax
    Whether exemption of HRA is allowed if rent is paid to any family members?
    ManualsIncome Tax
    What is the treatment of payment at the time of termination from un-recognised provident fund u/s 10...
    ManualsIncome Tax
    Whether a husband-wife both can claim LTA u/s 10(5)?
    ManualsIncome Tax
    Is it possible to claim LTA Twice in a Year u/s 10(5)?
    ManualsIncome Tax
    Can the Leave travel concession u/s 10(5) be carried forward?
    ManualsIncome Tax
    Can an individual claim the LTA u/s 10(5) in case of Switch of JOB?
    ManualsIncome Tax
    What type of expenses are covered under Leave Travel expense u/s 10(5)?
    ManualsIncome Tax
    Whether the exemption u/s 10(38) is avaliable if the transaction is undertaken on a stock exchange l...
    ManualsIncome Tax
    Whether Shares acquired as Gift from someone, are eligible for exemption u/s 10(38) at the time of s...
    ManualsIncome Tax
    Whether an enhanced compensation by any court or other authority shall be included u/s 10(37)?
    ManualsIncome Tax
    Whether the income on transfer of units is also exempt u/s 10(35)?
    ManualsIncome Tax
    Whether the exemption u/s 10(34A) on income arising due to buyback of shares applies on Long Term Ca...
    ManualsIncome Tax
    What are the cases where any sum received for life insurance policy u/s 10(10D) shall be exempt.
    ManualsIncome Tax
    What type of incomes shall be exempted u/s 10(8)?
    ManualsIncome Tax
    What are the conditions specified u/s 10(23A) for claiming exemption on Income of some Professional ...
    ManualsIncome Tax
    What are the conditions as specified u/s 10(21) to avail exemption of any income of a research assoc...
    ManualsIncome Tax
    As per section 10(19A), if the annual value of any one palace in the occupation of a former ruler, i...
    ManualsIncome Tax
    Whether any amount received as family pension by any member of the family of an individual who has b...
    ManualsIncome Tax
    A partner of the firm/LLP receives interest on capital and remuneration from the firm/LLP. Whether s...
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Notes
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    ManualsIncome Tax
    Show AI Summary
    HRA exemption: tenants without an HRA salary component may claim rent relief by meeting Section 80GG conditions.
    An individual who does not receive House Rent Allowance as part of salary may claim the deduction for rent paid under Section 80GG, provided the statutory conditions and documentation for that provision are met.
    ManualsIncome Tax
    Show AI Summary
    HRA exemption: rent paid to family members can qualify for tax relief, but payments to a spouse are not allowed.
    HRA exemption is available when an individual pays rent to family members and resides with them, provided the standard conditions for claiming HRA under salary exemptions are met; rent paid to a spouse is not accepted for HRA exemption.
    ManualsIncome Tax
    Show AI Summary
    Tax treatment of termination payments from unrecognised provident funds: employer contributions treated as salary; employee contributions exempt.
    Employee contributions on termination from an un-recognised provident fund are exempt from tax, while interest on those employee contributions is taxable as Income from Other Sources. Employer contributions and interest thereon are treated as salary income; recipients may claim available relief for the salary-characterised portion under the statutory relief mechanism for salary receipts.
    ManualsIncome Tax
    Show AI Summary
    Leave Travel Allowance exemption: spouses may each claim from their employers but not for the same journey.
    Both spouses may claim exemption for Leave Travel Allowance (LTA) from their respective employers as a salary-specific exemption, but both cannot claim exemption for the same journey.
    ManualsIncome Tax
    Show AI Summary
    Leave Travel Allowance (LTA) claim limited to one journey per year; two journeys in a block cannot both be claimed together.
    Leave Travel Allowance (LTA) under section 10(5) permits two journeys in a block of four years, but the exemption can be claimed for only one journey in a single year, so both journeys cannot be claimed in the same year.
    ManualsIncome Tax
    Show AI Summary
    Leave Travel Allowance carry forward permitted, claimable in first year of next block under income tax rules.
    Carry forward of Leave Travel Allowance under the income tax exemption regime is permitted when the allowance remains unused and may be claimed in the first year of the next block, preserving the tax-exempt benefit for the taxpayer into the subsequent block.
    ManualsIncome Tax
    Show AI Summary
    Leave Travel Allowance entitlement can be claimed from both current and former employer if prior LTA remains unutilized.
    An individual who switches jobs may claim Leave Travel Allowance (LTA) from both the current employer and the former employer provided the former employer's LTA concession remains unutilized; the entitlement is limited to recovery of that unutilized salary-specific exemption and does not extend beyond the unutilized LTA benefit.
    ManualsIncome Tax
    Show AI Summary
    Leave travel expense covers only the cost of travel; accommodation and meals are excluded from tax exemption.
    Leave travel benefits under section 10(5) are confined to the cost of travel itself and do not extend to ancillary expenses; incidental outlays such as food, hotel accommodation, and similar subsistence expenses are excluded from the scope of the travel expense exemption.
    ManualsIncome Tax
    Show AI Summary
    Exemption under section 10(38) available when transaction is on an IFSC exchange and consideration is in foreign currency.
    Exemption from long term capital gains under 10(38) applies despite non payment of Securities Transaction Tax if the transfer is on a recognised stock exchange in an International Financial Service Centre and the consideration is paid or payable in foreign currency.
    ManualsIncome Tax
    Show AI Summary
    Exemption under Section 10(38) applies to gifted shares on sale if the prior owner did not acquire them in a disqualifying manner.
    Shares received as a gift are eligible for exemption under Section 10(38) on sale, provided the previous owner did not acquire the shares in a manner or under conditions that disqualify them from the exemption.
    ManualsIncome Tax
    Show AI Summary
    Exemption for enhanced compensation confirms enhanced compensation falls within exempted compensation under income tax law.
    Enhanced compensation is treated as part of "compensation" for the purposes of the exemption under 10(37); amounts characterized as enhanced compensation are encompassed by the exemption framework and are not taxable under that provision, as stated in the income tax manual guidance on exempted income.
    ManualsIncome Tax
    Show AI Summary
    Income on transfer of units is not exempt under section 10(35); such transfer income remains taxable.
    Income arising on the transfer of units is not covered by the exemption under 10(35); proceeds from disposal of units are not exempt under that clause and must be treated as taxable transfer income under ordinary tax provisions.
    ManualsIncome Tax
    Show AI Summary
    Exemption on buyback income applies irrespective of short term or long term capital gains for shareholders under income tax law.
    The exemption on buyback income applies to a shareholder's receipt irrespective of the holding period; buyback proceeds are exempt from income tax in the shareholder's hands whether classified as short term or long term capital gains.
    ManualsIncome Tax
    Show AI Summary
    Life insurance exemption under section 10(10D) lists categories where policy receipts are fully tax-exempt from income tax.
    Exemption under Section 10(10D) covers amounts received on life insurance policies in defined categories: proceeds on insurance of a dependent handicapped person, proceeds under key man policies, and proceeds where annual premiums exceed specified proportions of the actual capital sum assured for policies issued in particular periods; proceeds under the premium ratio exceptions are stated to be fully exempt if received on the death of the person.
    ManualsIncome Tax
    Show AI Summary
    Income exemption under Section 10(8): foreign government remuneration for duties in India and foreign-sourced taxable income.
    Exemption under Section 10(8) covers two categories where agreements provide relief: remuneration paid by the foreign State for duties performed in India, and any other income arising outside India that the individual is required to tax as income or social security tax in that foreign State.
    ManualsIncome Tax
    Show AI Summary
    Exemption for professional institutions under section 10(23A) requires Central Government approval and exclusive application of income to objects.
    Exemption under section 10(23A) requires that an institution apply its income, or accumulate it for application, solely to the objects for which it is established, and that the institution be approved by the Central Government; both conditions are cumulative for claiming the exemption.
    ManualsIncome Tax
    Show AI Summary
    Exemption for research association income requires exclusive application to objects and permitted investments with corpus exceptions.
    Exemption requires that the research association apply its income, or accumulate it, wholly and exclusively to its objects, and that funds not be invested or deposited during the previous year except in forms permitted for trusts; exceptions to the investment restriction include assets forming part of the corpus, accretions to shares forming the corpus, and voluntary contributions maintained in kind such as jewellery or furniture.
    ManualsIncome Tax
    Show AI Summary
    Letting of former ruler's palace results in taxable income under section 10(19A), not eligible for exemption.
    If any palace or portion occupied by a former ruler is let out, the rent or annual value of that let-out portion is not exempt and is taxable rather than eligible for the exemption applicable to former rulers.
    ManualsIncome Tax
    Show AI Summary
    Family pension exemption shields dependents of government servants or decorated servicemen from taxable income under income tax law.
    Any amount received as family pension by members of the family of an individual who has been in Government service or has been awarded the Vir Chakra is fully exempted under the relevant income tax provision, and therefore excluded from the recipient's taxable income as an assessee-specific exemption.
    ManualsIncome Tax
    Show AI Summary
    Share of profit exemption: interest on capital and partner remuneration are not covered under the provision.
    The exemption is confined to a partner's share of profit from the firm or LLP and does not extend to interest on capital or to remuneration paid to the partner; such receipts must therefore be treated separately from the profit-share exemption.

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters
      Corporate Laws

      Small Industries Development Bank of India versus M/s. Sibco Investment Pvt. Ltd- Legal Position of NBFC in a civil suit.

      2 June, 2022

      Contents
      Acts
      Plus +
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      2022 (1) TMI 170 - Supreme Court

      Legal Position of NBFC in a civil suit.

      Section 45 MB of the RBI Act 1934. - Power of bank to prohibit acceptance of deposit and alienation of assets, Section 45 MC - Power of Bank to file winding up petition.

      Section 35A of the Banking Regulation Act, 1949 vests power in the RBI to give directions to banks and can take action, "to prevent the affairs of any banking company being conducted in a manner detrimental to the interests of the depositors or in a manner prejudicial to the interests of the banking company"

      A conjoint reading of the statutory provisions, makes it abundantly clear that for ‘public interest’ the RBI is empowered to issue any directive to any banking institution, and to prohibit alienation of an NBFC’s property.

      The term ‘Public interest’ has no rigid definition. It has to be understood and interpreted in reference to the context in which it is used. The concept derives its meaning from the statute where it occurs, the transaction involved, the state of society and its needs.

      It is not necessary for RBI to mention a specific provision before issuing directions, for it to have statutory consequences. All that is required is the authority under the law, to issue such direction.

      Therefore the RBI under Section 45-MB of the RBI Act, 1934 and 35-A of the Banking Regulation Act, 1949 has the requisite authority to issue the communication dated 09th June, 1997. Now the omission by the RBI to mention any enabling provision, doesn’t change the nature and status of the direction.

      The statutory arrangement and interpretation persuades to hold that actions in furtherance of grounds of ‘public policy’ by the RBI was justified, for issuing the Notification dated 10.04.1997. The notification itself clearly mentioned that it is issued for the benefit of "depositors and creditors" of CRB Capital.

      The actual status of the RBI Notification would have a bearing on the claim against the defendant in the suit and subsequent proceeding/s. The plaintiff, as can be noted, always had the option of challenging its legality but they have never specifically challenged those in the Suit. In a way the plaintiff " waived its right" by not challenging the RBI notification then/at that past point of time in the suit proceedings.

      The principle of waiver/acquiescence is applicable here.

      When the legality of the RBI Notification is not under challenge, relief can’t be granted in the Suit without determining its "legality". This in our perception can by itself, put a quietus on the issue at hand - the plaintiff cannot be granted parity with its predecessor-in-interest, Shankar Lal Saraf, who was paid interest which accrued in July, 1997 despite the RBI directive of 09.06.1997.

      The defendant defended this fallacy/aberration by clarifying that the payment to Shankar Lal Saraf was made before the defendant was in receipt of the RBI directive.

      Hence, the plaintiff cannot claim any advantage for themselves or parity with its predecessor-in-interest, on this cause. It amounted to sub-silencio acceptance.

      Suit barred by constructive res judicata.

      The cause of action for the plaintiff accrued the first time, when the defendant allegedly failed to pay timely interest. Since such a claim was not raised in the writ court, the subsequent Suit of SIBCO is barred by the principle of Constructive Res Judicata.

      Section 441(2) of the Companies Act, 1956 reveals that winding-up proceedings other than voluntary winding-up, are said to have commenced from the date of presentation of petition - A conjoint reading of Section 531 and 441(2) of the Companies Act, 1956 prima facie reveals that any transfer of property by or against a company in involuntary winding up, the suspect spell for deemed fraudulent transaction is six months before presentation of the winding up petition.

      In the present case, the petition for winding-up was submitted by RBI on 22.05.1997 and admittedly, the transfer in Shankar Lal Saraf’s favour was executed in February, 1997. The defendant’s contention as to the transfer being in the suspect spell, may be deemed fraudulent, cannot be rejected. 

      A question arose whether the present suit is barred by Constructive res judicata- It being decided that the cause of action for the plaintiff accrued the first time, when the defendant allegedly failed to pay timely interest. Since such a claim was not raised in the writ court/court of first instance, the subsequent Suit of SIBCO is barred by the principle of Constructive Res Judicata.

      This narrative makes us understand that a NBFC governed by the Banking  Regulation Act, 1949 and the  Reserve Bank of India Act, 1934 along with Section 531 and 441(2) of the Companies Act, 1956 is too subject to the common law principles and the Code of Civil Procedure, 1908 when in a civil suit before a Court of law.

       


      Full Text:

      2022 (1) TMI 170 - Supreme Court

      Topics

      ActsIncome Tax