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Commissioner of Income Tax-IV vs Stratex Networks (India) Pvt. Ltd. | Delhi High Court | Sections 92B, 92C, 92CA & 260A of Income Tax Act | Transfer Pricing – Whether Domestic Installation and Maintenance Transactions Can Be Included for Computing Profit Level Indicator (PLI) under TNMM
Facts of the
Case
The assessee, Stratex Networks (India) Pvt. Ltd., was a
wholly owned subsidiary of Digital Microwave (Mauritius) Ltd., which
itself was a subsidiary of Digital Microwave Corporation USA.
...
Commissioner of Income Tax-XVI vs Jaswinder Singh | Taxability of Salary Income of Foreign Employees and Interpretation of Residential Status under the Income Tax Act | Delhi High Court
Facts of the
Case
The Revenue filed appeals against various assessees including Sh.
Jaswinder Singh and other similarly situated individuals.
The disputes related to taxation of salary and employment income
...
Commissioner of Income Tax–III vs M/s Suren International Pvt. Ltd. | Delhi High Court | Reassessment u/s 147/148 Beyond Four Years Without Failure to Disclose Material Facts Invalid | Section 68 Share Application Money Case
Facts of the CaseM/s Suren International Pvt. Ltd. filed its return
of income declaring taxable income for Assessment Year 2002–03. The return was
initially processed under Section 143(1) and subsequently selected fo...
Bharat Sanchar Nigam Ltd. (BSNL) vs Deputy Commissioner of Income Tax & Ors. | Reassessment under Sections 147, 148 and Applicability of Explanation 10 to Section 43(1) – Delhi High Court
Facts of the
Case
BSNL was incorporated as a Government of India enterprise pursuant
to the National Telecom Policy, 1999 for taking over telecom operations
previously carried out by the Department of Tele...
Commissioner of Income Tax (C)-III vs Flex Foods Ltd. | Delhi High Court – Section 80HHC & Section 115JB: Treatment of Miscellaneous Income and Interest Income for Export Deduction Computation
Facts of the
CaseThe Revenue filed appeals before the Delhi High
Court against the common order passed by the Income Tax Appellate Tribunal
relating to Assessment Years 2003-04 and 2004-05. The issue raised was
regar...
Commissioner of Income Tax-(C)-III vs Flex Foods Ltd | Delhi High Court on Section 80HHC & Section 115JB – Treatment of Miscellaneous Income and Interest Income for Export Profit Deduction
Facts of the
Case
The Revenue filed appeals against the common order passed by the
Income Tax Appellate Tribunal for Assessment Years 2003-04 and 2004-05.
The Revenue contended that miscellaneous income and in...
Commissioner of Income Tax-XVI vs. Sh. Sashi Mukundan & Others [2013:DHC:3755-DB] – Delhi High Court Ruling on Expatriate Taxation and Salary Income
Facts of the
Case
The Revenue filed multiple connected appeals involving expatriate
employees and associated entities.
The disputes related to the tax treatment of salary income and
employment-related be...
Select Vacations Pvt. Ltd. vs Income Tax Officer & Anr. | Delhi High Court on Reassessment under Sections 147/148 of Income Tax Act – Change of Opinion and Full Disclosure Principle
Facts of the
CaseThe petitioner company was engaged in the business
of tours and travel services, including arranging tours, hotel bookings,
meetings, incentives and conferences.For Assessment Year 2006–07, the peti...
Maruti Suzuki India Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Reopening of Assessment u/s 147/148 Held Invalid on Mere Change of Opinion in Bad Debts Claim
Facts of the
CaseMaruti Suzuki India Ltd. filed its return for
Assessment Year 2003–04 and the assessment was completed under Section 143(3)
of the Income-tax Act. During the original assessment proceedings, the
As...
Yoshio Kubo v. Commissioner of Income Tax & Connected Matters – Delhi High Court on Employer-Paid Tax, Section 10(10CC), Social Security Contributions and Non-Monetary Perquisites
Facts of the
Case
Various foreign nationals and employees were deputed to India by
foreign corporations and group entities.
Their employers had undertaken obligations to bear:
Indian income tax liability...