Blog Categories
Subscribe to Newsletter
Join our subscribers list to get the latest Tax Updates and Opportunities.
PR. Commissioner of Income Tax–7 vs. Sharp Business Systems (India) Pvt. Ltd. | Delhi High Court | Bright Line Test in AMP Expenses Not Valid under Transfer Pricing Law (Section 92C, Income Tax Act)
Facts of the CaseThe present appeal was filed by the Revenue before the Delhi
High Court challenging the order of the Income Tax Appellate Tribunal (ITAT)
dated 10 December 2020 for Assessment Year 2011–12. The dispu...
Salil Gulati vs Assistant Commissioner of Income Tax, Circle 49(1) Delhi & Ors. – Validity of Reassessment Notice under Sections 148 & 149 of Income Tax Act in Light of TOLA and Ashish Agarwal Judgment (Delhi High Court, 2022)
Facts of the CaseThe Petitioner, Salil Gulati, filed a writ petition
challenging the order passed under Section 148A(d) and the reassessment notice
issued under Section 148 of the Income Tax Act, 1961 for Assessment Ye...
PR. Commissioner of Income Tax-1 vs Dentsply India Pvt. Ltd. | Delhi High Court | Section 92C Transfer Pricing | RPM vs TNMM | ITA 199/2022 (2022:DHC:2652-DB)
Facts of the
CaseAs per the judgment, the assessee, Dentsply India
Pvt. Ltd., is a wholly owned subsidiary engaged in manufacturing and trading
dental products. Approximately 95% of its business consisted of tra...
Tata Teleservices Limited vs Commissioner of Income Tax (IT), Delhi-3 & Ors. (2022:DHC:2775-DB) Delhi High Court | Stay of Demand | Section 201(1), 201(1A) of Income Tax Act | DTAA India–China | TDS on Interest Payments
Facts of the
CaseThe petitioner, Tata Teleservices Limited, filed a
writ petition challenging the order dated 2nd June 2022 passed by the
Commissioner of Income Tax (IT), Delhi-3, whereby the request for grant of stay...
Commissioner of Income Tax – International Taxation 3 vs Zaheer Mauritius (2022) – Taxability of Gains on Transfer of CCDs under India–Mauritius DTAA
Facts of the
Case
The appeal was filed by the Revenue challenging the order of the Income
Tax Appellate Tribunal (ITAT) dated 1 November 2019 for AY 2011–12.
The assessee, Zaheer Mauritius, earned gains fro...
M/s Huawei Telecommunications (India) Company Pvt. Ltd. vs Deputy Director of Income Tax (Inv.)-4(3), New Delhi & Ors. – Delhi High Court on Modification of Repatriation Restriction under Section 132(9B) of Income Tax Act
Facts of the CaseThe Petitioner, M/s Huawei Telecommunications (India)
Company Pvt. Ltd., filed a writ petition seeking modification of an interim
order dated 21 April 2022, whereby the Court had restrained the Petitio...
PR. Commissioner of Income Tax–7 vs Rayban Sun Optics India Ltd. | Delhi High Court | Bright Line Test & AMP Expenses | AY 2007-08
Facts of the Case
The
appeal was filed by the Revenue challenging the ITAT order dated
22.01.2021 for AY 2007-08.
The
ITAT relied on the decision in Sony Ericsson Mobile Communication vs.
CIT...
Celerity Infrastructure Pvt. Ltd. & Connected Matters vs Deputy Commissioner of Income Tax Circle 73(1), Delhi & Ors. (2022:DHC:2743-DB)
Facts of the
Case
Petitioners filed declarations under Forms 1 and 2 on 26
March 2021.
While filing, they inadvertently excluded the interest component
from the declared amount.
The department issued...
PR. Commissioner of Income Tax–7 vs. Sharp Business Systems (India) Pvt. Ltd. | Delhi High Court | Bright Line Test in AMP Expenses Not Valid under Transfer Pricing Law (Section 92C, Income Tax Act)
Facts of the CaseThe present appeal was filed by the Revenue before the Delhi
High Court challenging the order of the Income Tax Appellate Tribunal (ITAT)
dated 10 December 2020 for Assessment Year 2011–12. The dispu...
Celerity Infrastructure Pvt. Ltd. & Ors. vs Dy. Commissioner of Income Tax Circle 73(1), Delhi & Ors. (2022:DHC:2743-DB) – Rectification of Form 3 under DTVSV Act Cannot Be Denied on Technical Grounds
Facts of the
CaseThe petitioners, including Celerity Infrastructure
Pvt. Ltd. and various ATS group entities, filed declarations under the Direct
Tax Vivad se Vishwas Act, 2020 (DTVSV Act) through Forms 1 and 2 on 26t...