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Section 68 Additions Unsustainable When Identity, Creditworthiness & Genuineness Proved: Delhi High Court Dismisses Revenue Appeal in PCIT-9 v. Topline Buildtech Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the Income
Tax Act, 1961 challenging the order dated 13.04.2018 of the Income Tax
Appellate Tribunal (ITAT) for Assessment Year 2013-14.The respondent-...
ACIT, Allahabad vs. Mr. Denzil Richard Innis, St. John’s Co-Ed School (ITAT Allahabad): Revenue Appeals Dismissed on Low Tax Effect under CBDT Circular No. 3/2018 — Section 268A of the Income-tax Act
Facts of the CaseThe Revenue filed multiple appeals before the
Income Tax Appellate Tribunal, Allahabad challenging the orders passed by the
Commissioner of Income Tax (Appeals), Allahabad in respect of the block...
Interest from Head Office to Indian Branch Not Taxable: Delhi High Court Applies “No Profit from Self” Principle in CIT (IT)-3 v. Bank of Tokyo-Mitsubishi UFJ Ltd. (2024)
Facts of the CaseThe Revenue challenged the order of the Income Tax Appellate
Tribunal dated 30 January 2018 concerning Assessment Year 2003-04. The dispute
centered on whether interest received by the Indian Permanent...
No Writ Relief When Adequate Opportunity Given: Delhi High Court Upholds Section 153C Assessment in Sunita Goel v. DCIT Central Circle-1 (2024)
Facts of the CaseThe petitioner challenged the assessment order dated
22.04.2021 passed under Section 153C of the Income Tax Act, 1961 for Assessment
Year 2014-15, whereby ₹1,62,20,000 was added to her income.The pet...
ESOP Compensation Without Exercise Not Taxable as Salary: Delhi High Court Allows Nil TDS Claim in Sanjay Baweja v. DCIT (TDS) (2024)
Facts of the CaseThe petitioner, a former employee of Flipkart Internet Private
Limited, challenged an order dated 15.07.2023 passed under Section 197 of the
Income Tax Act, 1961 rejecting his application for a Nil Tax...
Assessment by Non-Jurisdictional AO Invalid Without Section 127 Transfer Order: Delhi High Court Quashes Proceedings in Raj Sheela Growth Fund Pvt. Ltd. v. ITO Ward-21(1) (2024)
Facts of the CaseThe principal issue before the Delhi High Court was whether a
non-jurisdictional Assessing Officer could proceed with assessment proceedings
in the absence of a transfer order under Section 127 of the ...
Vivad se Vishwas Benefit Allowed Even Without Pending Appeal: Delhi High Court in PT Bukaka Teknik Utama v. CIT (IT), Delhi-2 (2024)
Facts of the CaseThe petitioner, an Indonesian entity, challenged the rejection
of its declaration under the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act).
For Assessment Year 2010-11, the petitioner had filed its ...
Prakash & Co. vs. ACIT (ITAT): Tribunal Adjudicates Revenue Appeals and Assessee’s Cross-Objections on Additions and Appellate Relief under the Income-tax Act
Facts of the
CaseThe matter arose from assessment proceedings in
which the Assessing Officer made certain additions to the income of the
assessee, Prakash & Co. The assessee challenged these additions before the
...
Indian Subsidiary Not a Permanent Establishment: Delhi High Court Quashes Reassessment Notices in Progress Rail Locomotive Inc. v. DCIT (International Taxation) (2024)
Facts of the CaseThe writ petitions challenged reassessment notices issued
under Section 148 of the Income Tax Act, 1961 for Assessment Years 2012–13 to
2018–19 to Progress Rail Locomotive Inc. (formerly Electro Mo...
ITO (Exemption) Allahabad vs Hindi Sahitya Sammelan, Allahabad — ITAT Allahabad on Accumulation of Income Without Form 10, Compliance under
Facts of the
CaseThe assessee, a registered
educational and charitable society, reported substantial gross receipts during
the relevant assessment year. After incurring revenue expenditure and capital
spending, the s...