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Commissioner of Income Tax vs. International Tractors Ltd. Delhi High Court | ITA Nos. 1082/2005, 690/2008, 225/2009, 1189/2009 & 251/2010 | Judgment dated 20 July 2017 Section 80-IA, Section 147, Section 148, Section 263 & Section 40(a)(i) of the Income-tax Act, 1961 – Deduction to Small Scale Industrial Undertaking (SSI), Reassessment, Revisionary Jurisdiction and TDS on Reimbursement of Expenses
Facts of the CaseThe assessee, International Tractors Ltd., was
incorporated in 1995 and engaged in manufacturing and trading agricultural
tractors and tractor parts. It commenced production in Financial Year 1997-98
...
Canyon Financial Services Ltd. vs Income Tax Officer (Delhi High Court) – Scope of Section 153C of the Income Tax Act, 1961 | Requirement of “Belongs To” for Valid Satisfaction Note in Search Assessment Proceedings
Facts of the
CaseThe petitioner, Canyon Financial Services Ltd.,
challenged satisfaction notes dated 13 March 2014 and 19 March 2014 issued by
the Assessing Officers for initiating proceedings under Section 153C...
Delhi High Court | Sections 194-I, 201(1), 201(1A), 271C & 273B of the Income-tax Act, 1961 | TDS on Royalty vs Rent for Airport Lounge Operations | Whether Royalty Paid to AAI for Operating Executive Lounge Constitutes “Rent” Liable for TDS Deduction
Facts of the CaseThe Revenue preferred multiple appeals before the
Delhi High Court under Section 260A of the Income-tax Act against the order of
the Income Tax Appellate Tribunal (ITAT). The dispute arose from payment...
Commissioner of Income Tax vs International Tractors Ltd. | Section 80-IA Deduction for Small Scale Industrial Undertaking, Reassessment under Sections 147/148, Revision under Section 263 & Disallowance under Section 40(a)(i) | Delhi High Court
Facts of the CaseInternational Tractors Ltd. was incorporated in 1995 and
commenced manufacturing agricultural tractors and tractor parts in Financial
Year 1997-98. The assessee claimed deduction under Section 80-IA as...
Pr. Commissioner of Income Tax-6, New Delhi vs NBCC Ltd. | Delhi High Court on Reopening of Assessment under Section 147 without Fresh Tangible Material
Facts of the
CaseThe assessee, NBCC Ltd., had originally undergone
scrutiny assessment under Section 143(3) of the Income Tax Act, 1961 for
Assessment Year 2003–04.Subsequently, the Assessing Officer initiated...
Principal Commissioner of Income Tax (Central)-1 vs Sahara India Financial Corporation Ltd. | Delhi High Court Dismisses Revenue Appeals as Misconceived under Section 260A of the Income Tax Act, 1961
Facts of the CaseThe Revenue preferred multiple appeals before the Delhi High
Court under Section 260A against the impugned order dated 13 December 2016
passed by the Income Tax Appellate Tribunal. The ITAT had dismiss...
Commissioner of Income Tax vs I.T.C. Limited – Whether Royalty Paid to Airports Authority of India for Operating Executive Lounge Constitutes ‘Rent’ Liable for TDS under Section 194-I of the Income Tax Act, 1961 and Applicability of Interest under Section 201(1A) & Penalty under Section 271C
Facts of the CaseITC Limited was awarded a contract by Airports
Authority of India for operating an Executive Lounge at the International
Terminal of IGI Airport after a bidding process.A Licence Agreement was executed...
Pr. Commissioner of Income Tax-6, New Delhi vs NBCC Ltd. | Delhi High Court on Reassessment under Section 147 – Reopening Beyond Four Years Without Fresh Tangible Material Invalid
Facts of the
CaseThe present appeals were preferred by the Revenue
challenging the order passed by the Income Tax Appellate Tribunal (ITAT) in
relation to Assessment Year 2003–04. The Tribunal had allowed the
cross...
Principal Commissioner of Income Tax (Central)-1 vs Sahara India Financial Corporation Ltd. | Delhi High Court on Maintainability of Revenue Appeals Against Dismissal of Assessee’s Cross-Objections under Section 260A of the Income Tax Act, 1961
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High Court
under Section 260A of the Income Tax Act challenging the order dated 13
December 2016 passed by the Income Tax Appellate Tribunal (ITAT). ...
Principal Commissioner of Income Tax (Central)-1 vs Sahara India Financial Corporation Ltd. – Delhi High Court on Section 260A Income Tax Appeals and Binding Precedent in Revenue Matters
Facts of the CaseThe present batch of appeals was filed by the Revenue under Section
260A of the Income-tax Act, 1961 before the Delhi High Court challenging
the order dated 13 December 2016 passed by the Income Tax Ap...