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Zelos Developers Private Limited vs Assistant Commissioner of Income Tax Circle 25(1), Delhi (2022) – Reassessment Set Aside Due to Non-Consideration of Material Evidence under Sections 148A & 148 of Income Tax Act
Facts of the
CaseThe Petitioner challenged an order passed under
Section 148A(d) and a consequential notice issued under Section 148 for
Assessment Year 2016–17. The reassessment proceedings were initiated on the
a...
Commissioner of Income Tax (International Taxation)-2 vs. M/s Nagravision S.A. | Delhi High Court | Section 9(1)(vi) – Royalty on Software Supply Not Taxable
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 31 January 2022 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2017–18.The core issue pertained to the...
PR. Commissioner of Income Tax–7 vs M/s PTC India Financial Services Ltd (2022:DHC:3829-DB) – No Disallowance under Section 14A Where Investments Made from Own Funds | Delhi High Court
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 19.02.2021 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2010–11. The dispute arose on two key disall...
Pr. Commissioner of Income Tax-6 vs Macquarie Global Services Pvt. Ltd. (Delhi High Court) – Transfer Pricing | Exclusion of Comparables | No Substantial Question of Law
Facts of the
Case
The Assessee, Macquarie Global Services Pvt. Ltd., was
engaged in providing ITES services.
The matter relates to Assessment Year 2011–12.
The case was referred to the Transfer Pricing O...
Kamlesh Keswani vs Assistant Commissioner of Income Tax, Circle 49(1), Delhi (2022) – Reassessment u/s 148 Invalid on Change of Opinion & Section 54 LTCG Exemption Allowed on Joint Property Purchase | Delhi High Court
Facts of the
CaseThe petitioner sold a residential property located
at Defence Colony, New Delhi, for ₹2 crores and declared the same as Long Term
Capital Gain (LTCG) in his return. Subsequently, he purchased a new ...
PR. Commissioner of Income Tax (Central)-2 vs G.R. Goenka Education Society (2022) – Section 11 Exemption Allowed Despite Trademark Ownership Dispute | Delhi High Court
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), which
granted exemption under Section 11 of the Income Tax Act to the respondent
society...
Adroit Financial Services Pvt. Ltd. vs Assistant Commissioner of Income Tax Circle 1(1), Delhi & Ors. | Reassessment Beyond Limitation Held Invalid under Section 149(1)(b) – Delhi High Court
Facts of the
CaseThe petitioner filed a writ petition challenging:
Notice dated 7 April 2021 issued under Section 148A(b)
Order dated 29 July 2022 passed under Section 148A(d)
Reassessment notice dated 29 July 2...
North End Foods Marketing Pvt. Ltd. vs Deputy Commissioner of Income Tax Circle 16(1), Delhi (2022:DHC:4024-DB)
Facts of the
CaseThe petitioner, North End Foods Marketing Pvt.
Ltd., challenged the order passed under Section 148A(d) and the consequential
notice issued under Section 148 of the Income Tax Act for Assessment Year
...
PR. Commissioner of Income Tax (Central)-2 vs. M/s JPM Tools Ltd. & Connected Matters (Delhi High Court, 2022) – Section 153A Additions Without Incriminating Material Held Invalid
Facts of the
CaseThe Revenue filed multiple appeals against a common
ITAT order relating to Assessment Years 2008–09 to 2011–12. The dispute
arose from additions made by the Assessing Officer under Section 68 on a...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Group Companies (Delhi High Court, 2022) – Section 153A Additions Without Incriminating Material Invalid
Facts of the
Case
The Revenue filed multiple appeals against a common ITAT order
concerning several group companies for different assessment years.
The additions were made primarily on account of:
Alle...