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Commissioner of Income Tax-VI vs Climate System Pvt. Ltd. | Allowability of Foreign Exchange Fluctuation Loss on FCNR(B) Loan under Sections 37(1), 43A & 263 of the Income Tax Act, 1961
Facts of the CaseThe assessee had issued 15% Unsecured Redeemable
Non-Convertible Debentures carrying interest at 15% per annum. For repayment of
these debentures, the assessee obtained FCNR(B) loans from banks at lowe...
JRD Stock Brokers (P) Ltd. vs Commissioner of Income Tax-II | Delhi High Court | Section 154 & Section 132 of Income Tax Act | Rectification of Mistake Cannot Be Used for Reassessment of Turnover in Accommodation Entry Cases
Facts of the CaseThe assessee was subjected to a search under Section 132 on
24 November 2000 for allegedly providing accommodation entries in the form of
bogus share gains and losses.It was found that the assessee ope...
Commissioner of Income Tax vs. M/s Navodaya Castles Pvt. Ltd. – Addition under Section 68 on Bogus Share Capital / Accommodation Entries – Delhi High Court
Facts of the Case
The
assessee company filed its return declaring loss for Assessment Year
2002-03.
The
case was reopened under Sections 147/148 based on Investigation Wing
information allegi...
Commissioner of Income Tax–III vs. M/s R.R. Holdings Pvt. Ltd. (2014) 2014:DHC:4097-DB | Delhi High Court | Section 217(1A) Interest Levy on Failure to Pay Advance Tax
Facts of the CaseThe assessee company filed its
return for Assessment Year 1988-89 declaring a loss. During assessment
proceedings, the assessee requested that consultancy commission income
amounting to Rs.1,82,69,610...
Director of Income Tax (Exemption) vs The Ajay G. Piramal Foundation – Corpus Donation of Shares, Exemption under Sections 11, 12 & 13(1)(d) of the Income Tax Act, Validity of Revised Return and Taxability of Gifted Shares | Delhi High Court
Facts of the CaseThe Ajay G. Piramal Foundation was established on 30.07.2005
for charitable purposes including establishment and operation of hospitals,
medical institutions, dispensaries, maternity homes and child we...
M/s Galileo Nederland BV (Now Travelport Global Distribution System BV) vs Assistant Director of Income Tax, Circle-1(2), International Tax, New Delhi | Delhi High Court | Profit Attribution to PE in India under Section 9(1)(i) & Article 7 of Indo-Netherlands DTAA
Facts of the Case
The
assessee, incorporated in the Netherlands, was engaged in providing
electronic distribution services to the travel industry through a
Computerised Reservation System (CRS).
Th...
Rashda Siddiqui vs Commissioner of Income Tax-VIII, New Delhi & Ors. | Taxability of Sale of Paintings as Personal Effects under Section 2(14) of the Income Tax Act
Facts of the Case
The
petitioner sold a painting during the financial year relevant to
Assessment Year 2006-07 for Rs. 34 lakhs.
The
painting had been acquired prior to 01.04.1981.
The
pet...
Commissioner of Income Tax-II vs M.G. Share & Stock Pvt. Ltd. | Delhi High Court | Short Term Capital Gain vs Business Income on Share Transactions | Sections 28 & 45 of Income Tax Act
Facts of the Case
The
assessee was a registered sub-broker with SEBI.
The
assessee filed return declaring:
Business
income from trading in shares: Rs. 21,40,752/-
Long-term
capit...
Mantola Co-Operative Thrift & Credit Society Ltd. vs Commissioner of Income Tax – Interest on Surplus FDR Deposits Taxable as “Income from Other Sources” Under Sections 80P & 56 of Income Tax Act
Facts of the CaseThe appellant, Mantola Co-Operative Thrift & Credit
Society Ltd., was engaged in providing credit facilities to its members. During
Assessment Year 2008-09, the society earned substantial interest ...
Commissioner of Income Tax vs. Raghubir Singh Garg | Validity of Satisfaction Note under Sections 158BD & 158BC after Completion of Block Assessment | Delhi High Court
Facts of the CaseA search and seizure operation under Section 132 of the
Income-tax Act was conducted on 3 August 2000 against Mr. Manoj Aggarwal and
M/s Friends Portfolio Pvt. Ltd.Subsequently:
Block
assessmen...