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Commissioner of Income Tax (International Taxation)-2 vs. M/s Nagravision S.A. (Delhi High Court, 2022) – No Royalty on Supply of Software under Section 9(1)(vi) & India-Switzerland DTAA
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 dispute arose regarding the...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation (2022:DHC:3803-DB) – Transponder Charges Not Taxable as Royalty under Section 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue before the
Delhi High Court challenging the orders passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2014–15 and 2015–16. The cor...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation | Delhi High Court (2022) – Transponder Charges Not Taxable as Royalty u/s 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue challenging
the orders passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Years 2014–15 and 2015–16. The dispute pertains to whether pay...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Batch Matters (Delhi High Court) – Section 153A Additions Without Incriminating Material Invalid
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging a common order of the Income Tax Appellate Tribunal (ITAT)
relating to multiple assessment years of various group companies.A search w...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Connected Matters | Delhi High Court | Section 153A & 68 Income Tax Act | No Addition Without Incriminating Material
Facts of the CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common ITAT order dated 23.12.2021 concerning
various assessment years (AY 2008–09 to AY 2011–12). The dispute arose fro...
Paramount Polymers Pvt. Ltd. vs Assistant Commissioner of Income Tax, Circle-19(1), New Delhi & Anr. (2022:DHC:3913-DB)
Facts
of the CaseThe
petitioner challenged the order dated 31 July 2022 passed under Section 148A(d)
along with a notice issued under Section 148 of the Income Tax Act for
Assessment Year 2017–18. The
reassessment...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Ors. | Delhi High Court | Section 153A, 68 Income Tax Act | No Addition Without Incriminating Material
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging a common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning multiple assessment years. The dispute arose from a searc...
Pr. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Connected Appeals (Delhi High Court) – Section 153A Additions Without Incriminating Material Not Sustainable
Facts of the Case
A search and seizure operation was conducted on the assessee group.
Assessments for relevant years had already attained finality prior
to the search.
The Assessing Officer made...
PR. Commissioner of Income Tax (Central)-2 vs. M/s JPM Tools Ltd. & Group Companies (Delhi High Court) – No Addition u/s 153A Without Incriminating Material
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging a common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning multiple assessment years of the respondent companies (JP...
PR. Commissioner of Income Tax (Central)-2 vs Panchmukhi Management Services Pvt. Ltd. | Delhi High Court | Section 153C – Incriminating Material Requirement & Validity of Protective Additions
Facts of the
Case
The Revenue filed appeals challenging the ITAT order dated
28.02.2022, which deleted protective additions made in the
hands of the assessee.
A search and seizure operation under Sectio...