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PR. Commissioner of Income Tax-7, Delhi vs Meera Gupta (Delhi High Court, ITA 403/2023, 405/2023 & 406/2023) – No Addition in Absence of Incriminating Material in Completed Assessments under Search Proceedings
Facts of the CaseThe present appeals were filed by the Revenue before the Delhi
High Court against the order of the Income Tax Appellate Tribunal (ITAT) dated
12.10.2022 concerning Assessment Years 2009-10, 2011-12, an...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Cognyte Technologies Israel Ltd. (Formerly Verint Systems Ltd.) – Delhi High Court (2023) | Taxability of Software Payments as Royalty under Section 9(1)(vi) & India-Israel DTAA
Facts of the Case
The
case pertains to Assessment Year 2012–13.
The
respondent/assessee, a company incorporated in Israel, received
consideration from Indian entities, including Wipro Ltd., for t...
PR. Commissioner of Income Tax, Delhi–7 vs M/s Omniglobe Information Technologies (India) Pvt. Ltd. (Delhi High Court) – Section 92CA, 143(3), 144C | Transfer Pricing – Exclusion of KPO Comparables in ITES/BPO Services
Facts of the CaseThe present appeal pertains to Assessment Year 2012–13, where
the assessee, a wholly owned subsidiary of a US-based entity, was engaged in
providing IT-enabled services (ITES)/BPO services such as ph...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Cognyte Technologies Israel Ltd. (Formerly Verint Systems Ltd.) – Delhi High Court | Off-the-Shelf Software Not Royalty u/s 9(1)(vi) & Article 12 DTAA
Facts of the CaseThe respondent/assessee, Cognyte Technologies Israel Ltd.,
a company incorporated in Israel, received consideration from Indian customers,
including Wipro Ltd., for the sale of software during Assessme...
PR. Commissioner of Income Tax-7, Delhi vs Meera Gupta | No Additions in Completed Assessments without Incriminating Material u/s 153A | Delhi High Court
Facts of the CaseThe present appeals were filed by the Revenue before the Delhi
High Court challenging the order of the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2009–10, 2011–12, and 2...
Dish TV India Limited vs Directorate General of Income Tax & Ors. – Delhi High Court (2023) | W.P.(C) 10472/2023 | Representation & Natural Justice in Tax Proceedings
Facts of the CaseThe petitioner, Dish TV India Limited, filed a writ
petition before the Delhi High Court, seeking limited relief in relation
to proceedings involving the Directorate General of Income Tax and other
re...
PR. Commissioner of Income Tax-7, Delhi vs Meera Gupta | No Addition in Absence of Incriminating Material in Completed Assessments (Sections 153A/143 of Income Tax Act)
Facts of the CaseThe appeals were filed by the Revenue against the order of
the Income Tax Appellate Tribunal (ITAT), which had ruled in favor of the
assessee, Meera Gupta.The Tribunal observed that no incriminating ma...
Darpan Kohli vs Assistant Commissioner of Income Tax | Delhi High Court | Section 271F Income Tax Act | Penalty Notice Set Aside
Facts of the CaseThe petitioner, Darpan Kohli, approached the High Court
challenging a show-cause notice dated 11.07.2023 issued under Section
271F of the Income Tax Act for imposition of penalty for Assessment Year
2...
PR Director General of Income Tax (Admn & TPS) vs M/s The Indian Plywood Manufacturing Co. Pvt. Ltd. & Anr. – Scope of BIFR Scheme Modification and Tax Concessions under SICA & Income Tax Act
Facts of
the CaseThe respondent company was declared a sick industrial company
and a rehabilitation scheme was sanctioned by BIFR under SICA. The scheme
included tax concessions to be considered by the Income Ta...
Banyan Real Estate Fund Mauritius vs Assistant Commissioner of Income Tax Circle International Tax 1(1)(2) & Anr – Reassessment Proceedings Stayed due to Non-Application of Mind under Sections 148A(b), 148A(d) & 148 of Income Tax Act, 1961
Facts of
the CaseThe present writ petition arises from reassessment proceedings
initiated by the Assessing Officer (AO) under Section 148A(b) of the Income Tax
Act, 1961 for AY 2016–17.The AO alleged that the ...