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Reassessment Valid Where Risk Management Information Indicates Bogus Purchases and AO Applies Mind under Section 148A: No Interference in Writ Jurisdiction – R S Alloys vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, R S Alloys, a partnership firm
engaged in trading of ferrous and non-ferrous metals, filed its return of
income for Assessment Year 2019–20 under Section 139(1) of the Income-tax Act,...
Disallowance under Section 40(a)(i) Barred by Non-Discrimination Clause under DTAA; No TDS Obligation Where Income Not Chargeable to Tax: Revenue Appeal Dismissed – PCIT-04 vs. Mitsubishi Corporation (India) Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 12.08.2022 passed by the
Income Tax Appellate Tribunal in ITA No. 9364/Del/2019 for Assessment Yea...
Interest on FDRs Earned from Project-Linked Funds Is Capital Receipt and Not Income from Other Sources: Revenue Appeal Dismissed – PCIT-1 vs. Brahma Center Development Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 17.07.2023 passed by the
Income Tax Appellate Tribunal, Delhi Bench, allowing the appeal of the
a...
AMP Expenses Not an International Transaction; Bright Line Test Impermissible; Revenue Appeals Dismissed – PCIT-1 vs. Casio India Co. Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of
the Income-tax Act, 1961 challenging the common order dated 24.02.2020 passed
by the Income Tax Appellate Tribunal, Delhi Bench, deciding ITA Nos.
385/D...
ITAT Justified in Remanding Subsidy Taxability Pending Supreme Court Decision; After-Sales Provision Allowable on Scientific Basis – PCIT Noida vs. Triveni Engineering (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 29.01.2025 passed by the
Income Tax Appellate Tribunal, which disposed of twelve appeals relating ...
No Depreciation Disallowance on Discarded Assets within Block; AMP Adjustment Unsustainable; Revenue Appeal Dismissed – PCIT-7 vs. Sony India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 30.08.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2010-11. The Tribunal h...
Jurisdictional Assessing Officer Competent to Initiate Reassessment Despite Faceless Scheme; Writ Dismissed Following TKS Builders – Neena Wadhwa vs. PCIT (Delhi HC)
Facts of the CaseThe petitioner, Neena Wadhwa, filed a writ
petition challenging the notice dated 20.03.2024 issued under Section 148A(b)
of the Income-tax Act, 1961, the approval dated 30.03.2024 granted under
Sectio...
Jurisdictional Assessing Officer Has Concurrent Power to Initiate Reassessment Despite Faceless Regime; TKS Builders Followed – M/s Empire Fasteners vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, M/s Empire Fasteners, filed two
writ petitions challenging the order dated 27.06.2025 passed under Section
148A(3) of the Income-tax Act, 1961 and the consequential notice dated
27.06....
Department Directed to Release Refund with Interest Within Eight Weeks; Liberty Granted to Seek Revival if Shortfall Persists – Anil Kumar Goel vs. PCIT (Delhi HC)
Facts of the CaseThe petitioner, Mr. Anil Kumar Goel, approached
the Delhi High Court seeking issuance of a writ of mandamus directing the
Income Tax Department to issue consequential refunds in compliance with the
or...
Reassessment for AY 2013–14 Remanded to AO to Examine Surviving Period under Amended Law; Rajeev Bansal and Ram Balram Buildhome Applied – Mahendra Kumar Jhanwar vs. ITO (Delhi HC)
Facts of the CaseThe petitioner challenged the initial notice dated
17.06.2021 issued under Section 148 of the Income-tax Act, 1961 under the old
regime, the subsequent notice dated 28.05.2022 issued under Section 148A...