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M/s Asian Hotels Ltd. vs Commissioner of Income Tax-I (Delhi High Court, 2023) – Renovation & Repair Expenses: Capital vs Revenue under Section 37 of Income Tax Act
Facts of the
Case
The assessee, M/s Asian Hotels Ltd., operated a five-star
hotel (Hyatt Regency, Delhi).
It undertook extensive renovation, refurbishment, and repair
work after several years of operati...
Commissioner of Income Tax (International Taxation)-3 vs Standard Chartered Grindlays Pty Ltd (Delhi High Court) – Penalty u/s 271(1)(c) Not Sustainable When Quantum Additions Deleted
Facts of the
CaseThe Revenue filed an appeal challenging the order
of the Income Tax Appellate Tribunal (ITAT), which had set aside the penalty
imposed on the assessee under Section 271(1)(c) of the Income-tax Act for...
M/s Asian Hotels Ltd vs Commissioner of Income Tax (Delhi High Court) – Section 37 | Renovation & Consultancy Expenses as Revenue Expenditure
Facts of the
CaseThe appellant/assessee, M/s Asian Hotels Ltd,
incurred substantial expenditure on renovation, refurbishment, and repairs
of its existing hotel property during the Assessment Year 1994–95.
Additiona...
M/s Asian Hotels Ltd. vs Commissioner of Income Tax – Deductibility of Renovation & Consultancy Expenses under Section 37 of Income Tax Act
Facts of the
CaseThe appellant, M/s Asian Hotels Ltd.,
incurred expenditure towards renovation, repair, and refurbishment of its
existing hotel property.A sum of ₹11,00,000 was paid to Gherzi
Eastern Ltd. (GEL) for...
Principal Commissioner of Income Tax-4 vs GE India Business Services Pvt. Ltd. (Delhi High Court) – Transfer Pricing Issues Covered by Rampgreen Solutions Case
Facts of the
Case
The appeal was preferred by the Revenue against the ITAT order.
The dispute relates to transfer pricing adjustments for AY 2009–10.
The Revenue aimed to challenge the Tribunal’s findi...
Principal Commissioner of Income Tax-3 vs Fujitsu India Pvt. Ltd. – RPM vs TNMM in Transfer Pricing for Pure Distributor (Delhi High Court)
Facts of the
CaseThe assessee, Fujitsu India Pvt. Ltd., was engaged
in distribution activities, purchasing goods from its associated enterprises
(AEs) and reselling them in India without any value addition.The Transfe...
PR. Commissioner of Income Tax-3 vs Fujitsu India Private Limited (Delhi High Court) – Applicability of Resale Price Method (RPM) vs TNMM for ALP Determination under Sections 144C & 143(3)
Facts of the
CaseThe case pertains to Assessment Years 2011-12,
2012-13, and 2013-14, where the Assessing Officer passed orders under Section
144C read with Section 143(3). The Transfer Pricing Officer (TPO) determine...
PR. Commissioner of Income Tax–3 vs Fujitsu India Pvt. Ltd. | Delhi High Court | Section 144C r/w 143(3) | Transfer Pricing – RPM vs TNMM for ALP Determination
Facts of the
CaseThe present matter pertains to appeals filed by the
Revenue against Fujitsu India Private Limited for Assessment Years 2011–12,
2012–13, and 2013–14.The Assessing Officer (AO) passed assessment ...
The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)
Facts of the CaseThe Revenue filed an appeal against the order of
the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the
Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...
The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)
Facts of the CaseThe Revenue filed an appeal against the order of
the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the
Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...