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ATSUSHI YOSHIDA & ORS. Vs. ASSISTANT COMMISSIONER OF INCOME TAX Reopening of Assessment under Section 147/148 | Validity of Notice after Expiry of Section 143(2) Timeline | Processing under Section 143(1) vs. Regular Assessment
Facts of the Case
Employment
and Salary Terms: The petitioners were employees of M/s
Tokio Marine and Nichido Fire Inc. Limited and were paid tax-free salaries
in India, with the income tax component ...
SQL Star International Ltd. vs. Deputy Commissioner of Income Tax (Validity of Reassessment Proceedings under Sections 147/148 of the Income Tax Act, 1961: Mandatory Requirement of a Reasoned Speaking Order Disposing of Assessee Objections)
Facts of the Case
Assessee
& Assessment Years: The petitioner, SQL Star
International Ltd., is a corporate entity assessed under the Income Tax
Act, 1961. The case pertains to two separate Assessm...
Commissioner of Income Tax vs. Monto Motors Ltd. | Appeal Under Section 260A of the Income Tax Act, 1961 Regarding the Classification of Ongoing Advertisement and Sales Promotion Expenditures as Revenue Expenditure versus Capital Outlay
Facts of the Case
The
respondent-assessee, M/s Monto Motors Ltd., was incorporated in 1998 and
engaged in the business of manufacturing and marketing mopeds and
motorcycles.
During
the Assess...
Commissioner of Income Tax vs. Wimco Seedlings Ltd. | Disallowance of Expenditure under Section 14A of the Income Tax Act, 1961 regarding Allocation of Common Expenses towards Taxable and Non-Taxable (Exempt) Income
Facts of the Case
Appeals
and Assessment Years: The Revenue (Commissioner of Income
Tax) filed three interconnected appeals (ITA Nos. 1367/2008, 1368/2008,
and 1391/2008) against a common judgment of ...
Commissioner of Income Tax vs. Wimco Seedlings Ltd.: Legal Validity of Allocating and Apportioning Common Business Expenses Incurred by an Assessee Toward Taxable and Non-Taxable Income Streams Under Section 14A of the Income Tax Act, 1961
Facts of the Case
The
Revenue filed three interconnected appeals (ITA Nos. 1367/2008, 1368/2008,
and 1391/2008) targeting a consolidated order passed by the Income Tax
Appellate Tribunal (Tribunal) on...
Commissioner of Income Tax vs. Wimco Seedlings Ltd.: Allocation of Common Expenses and Disallowance Under Section 14A of the Income Tax Act, 1961 – Scope of "In Relation To" and Application of Judicial Consistency vs. Precedent in Maxopp Investment Ltd.
Facts of the Case
The
Revenue filed three appeals against a common judgment of the Income Tax
Appellate Tribunal (ITAT) dated 22.02.2008.
The
appeals correspond to multiple assessment years: ITA No...
Commissioner of Income Tax v. M/s EHPT India Private Limited: Validity of Head-Count Method for Allocation of Indirect Expenses Between Tax-Exempt STP and Taxable Non-STP Units and the Applicability of the Rule of Consistency Under Section 10A of the Income-Tax Act, 1961
Facts of the Case
The
Assessee's Business: The respondent-assessee is a private
limited company resident in India. During the assessment years (AY)
2001-02 and 2002-03, it operated two distinct busine...
Commissioner of Income Tax vs. M/s Thirani Chemicals Ltd.: Whether Expansion of Existing Production Capacity Constitutes Setting Up of a New Industrial Undertaking for Eligibility of Deductions Under Sections 80HH and 80I of the Income Tax Act, 1961
Facts of the Case
Appeals
Filed: The revenue/appellant filed two appeals before the High
Court: ITA No. 1006/2005 (for the Assessment Year 1994-1995) and ITA
No. 457/2007 (for the Assessment Year 1996...
Commissioner of Income Tax vs. EHPT India P. Ltd. | Section 10A Indirect Expenses Apportionment: Head-Count vs. Turnover Method
Facts of the Case
The
Assessee: The respondent-assessee is an Indian private
limited company that operated two distinct divisions during the relevant
assessment years (AY 2001-02 and AY 2002-03):
...
Commissioner of Income Tax vs. EHPT India P. Ltd. | Section 10A Indirect Expenses Apportionment: Head-Count vs. Turnover Method
Facts of the Case
The
Assessee: The respondent-assessee is an Indian
private limited company that operated two distinct divisions during the
relevant assessment years (AY 2001-02 and AY 2002-03):
...