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Pr. Commissioner of Income Tax-2 vs. Natural Products Bio Tech Ltd.: Analysis of Section 153C Satisfaction Requirements
Facts of the Case
Search
and Seizure: A search operation was conducted at the premises of an entity
named "Global Heritage Venture Pvt. Ltd.".
Discovery
of Material: During this search, a hard disc...
Commissioner of Income Tax vs Vishishth Chay Vyapar Ltd. (Delhi High Court) – Bogus Share Loss, Sham Transactions and Disallowance under Section 73 of the Income Tax Act
Fact of the CaseThe
dispute arose from assessment years 1997–98, 1998–99, and 1999–2000 where the
assessee claimed substantial losses on account of purchase, sale, and
diminution in the value of shares held as s...
Commissioner of Income Tax, Delhi vs Commer and Associates Pvt. Ltd.
Facts of the
CaseThe assessee, Commer and Associates Pvt. Ltd.,
was engaged in activities connected with export business and earned commission
from Indian parties for transferring/procuring export orders.The assessee ...
Principal Commissioner of Income Tax-21 Delhi vs. Ashok Kumar: Determination of Share Trading Income vs. Capital Gains under Section 260A
Facts of the CaseThe dispute originated from the Assessing Officer's (AO)
determination that the assessee's income from share trading should be treated
as "business income" rather than "capital gains". The
assessee di...
Commissioner of Income Tax vs Vishishth Chay Vyapar Ltd. – Bogus Share Loss, Sham Transactions & Allowability of Share Trading Loss under Section 73 of the Income Tax Act
Facts of the CaseThe
present appeals were filed by the Revenue under Section 260A of the Income
Tax Act, 1961 against the common order of the Income Tax Appellate Tribunal
(ITAT), whereby the Tribunal upheld the order...
Commissioner of Income Tax (Central)-I vs. M/S Yash Pal Narender Kumar | Delhi High Court Ruling on Condonation of Delay and Protective Additions under Section 153C
Facts of
the CaseThe Revenue (Commissioner of Income Tax) filed three distinct
appeals (ITA 254/2015, ITA 255/2015, and ITA 256/2015) before the Delhi High
Court against the Respondent, M/S Yash Pal Narender Kumar. Th...
M/s Trimatic Engineering Co. Pvt. Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court) – Deduction under Section 80-I Allowed on Contract Labour Employment
Facts of the
CaseThe assessee company, engaged in manufacturing
activities, claimed deduction under Section 80-I amounting to Rs. 92,251/-
being 25% of its profits for Assessment Year 1986–87. The assessee had emplo...
Commissioner of Income Tax v. Eicher Ltd. | Section 43B of the Income Tax Act – Conversion of Interest Liability into Term Loan Does Not Amount to Actual Payment (Delhi High Court)
Facts of the CaseThe
assessee, M/s Eicher Ltd., had outstanding interest liabilities payable to
financial institutions including IFCI, IDBI, and HDFC Bank. Instead of making
direct payment of the interest amount, the ...
Legal Nullity of Tax Notices Against Amalgamated Entities: A Critical Analysis of Pr. Commissioner of Income Tax vs. Images Credit and Portfolio Pvt. Ltd. Section 260A
Facts of the CaseFollowing a search and seizure operation conducted under
Section 132 of the Income Tax Act, 1961, on October 20, 2008, against B.K.
Dhingra and others, documents belonging to the Respondent company, Im...
Commissioner of Income Tax vs. Vishishth Chay Vyapar Ltd. | Delhi High Court on Bogus Share Losses, Sham Transactions & Section 73 of Income Tax Act
Facts of the CaseThe assessee company
claimed substantial losses in multiple assessment years (1997–98, 1998–99, and
1999–2000) arising from purchase, sale, and diminution in the value of shares
held as stock-in...