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Commissioner of Income Tax vs. Tadashi Murakami (Delhi High Court) – Grossing Up under Section 195A Not Permissible Where Advance Tax is Paid by Employee; Employer-Paid Tax Treated as Non-Monetary Perquisite

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 52
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Facts of the CaseThe assessee, Mr. Tadashi Murakami, was an employee of Hongo India Pvt. Ltd. He received salary in both Indian currency and foreign currency. Apart from salary, tax amounting to Rs. 1,68,104/- was pai...

Commissioner of Income Tax vs Singapore Airlines Ltd (and Consolidated Appeals): Whether Supplementary Commission and Incentive/Discount Earned by Travel Agents on Air Tickets Attract TDS Liabilities Under Section 194H of the Income Tax Act, 1961

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 47
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1. Facts of the Case Parties Involved: The bunch of appeals was preferred by the Commissioner of Income Tax, New Delhi (Appellant / Revenue) against multiple domestic and international airlines, inclu...

Commissioner of Income Tax vs. M/S. Dalmia Agencies (P) Ltd.: Penalty Under Section 271(1)(c) Not Maintainable for Bona Fide Claim of Business Expenditure Under Section 37(1) vs. Section 35DDA

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 37
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Facts of the Case·         The assessee, M/S. Dalmia Agencies (P) Ltd., filed its return of income for the Assessment Year (AY) 2001-02, declaring a loss of ₹44,37,666.·&nb...

Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others (With CIT vs. Lufthansa German Airlines): Applicability of TDS Under Section 194H on Supplementary Commission vs. Trade Discounts on Concessional Tickets in Airline Industry

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 38
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Facts of the CaseThe Revenue preferred a batch of appeals against several international and domestic airlines (including Singapore Airlines, KLM Royal Dutch Airlines, British Airways, Air France, and Lufthansa German ...

Commissioner of Income Tax, Delhi-VIII vs Mukesh Luthra – Reopening of Assessment under Sections 147/148 Invalid Where No Tangible Material Existed to Deny Section 80HHC Deduction

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 33
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Facts of the CaseThe assessee, Mukesh Luthra, claimed deduction under Section 80HHC of the Income-tax Act, 1961 in respect of export income. The Assessing Officer (AO) initiated reassessment proceedings by issuing no...

Commissioner of Income Tax v. Singapore Airlines Ltd. & Others (ITA No. 306/2005): Applicability of Section 194H on Supplementary Commission and Concessional Tickets in the Aviation Sector

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 39
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Facts of the Case Reintroduction of Section 194H: Section 194H was reintroduced into the statute book by the Finance Act, 2001, effective from June 1, 2001. Following this, the Income Tax Department d...

Commissioner of Income Tax-II vs. Jagson International Ltd (ITA Nos. 57 & 341/2009): Delhi High Court Holds That No Fresh Substantial Question of Law Arises When the Same Issue Has Already Been Decided Between the Same Parties Under Section 260A of the Income Tax Act, 1961

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 37
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Facts of the CaseThe Revenue (Appellant) filed appeals (ITA Nos. 57/2009 and 341/2009) before the Hon’ble Delhi High Court against the orders passed in favor of the assessee, M/s Jagson International Ltd (Responden...

Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others: Applicability of TDS under Section 194H on Supplementary Commission and Concessional Tickets of Foreign Airlines

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 45
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Facts of the Case Parties & Group Appeals: This case involves a batch of appeals filed by the Revenue (Commissioner of Income Tax) against various international air carriers including Singapore Ai...

Commissioner of Income Tax, Delhi-VIII vs. Mukesh Luthra – Reassessment under Sections 147/148 Invalid in Absence of Tangible Material; Export Receipts Supported by FIRCs Eligible for Deduction under Section 80HHC

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 36
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Facts of the CaseThe present case involved the validity of reassessment notices issued by the Assessing Officer (AO) under Sections 147 and 148 of the Income-tax Act, 1961, for Assessment Years 1997-98, 1998-99 and 1...

Commissioner of Income Tax, New Delhi vs. Singapore Airlines Ltd. (along with connected matters including KLM Royal Dutch Airlines, British Airways PLC, Air India Ltd., Lufthansa German Airlines, etc.).

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My Tax Expert
12/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 38
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Facts of the Case The Revenue preferred a batch of appeals against various international and domestic airlines operating in India. A survey under Section 133A revealed that the assessee-airlines su...