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M/s JBM Industries Ltd. vs Commissioner of Income Tax, New Delhi (2019) – Disallowance of Educational Expenses under Section 37(1) of the Income Tax Act
Facts of the CaseThe appellant, M/s JBM Industries Ltd., filed multiple
appeals against a composite order passed by the Income Tax Appellate Tribunal
concerning Assessment Years 2001–02 to 2004–05. The primary issu...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Cannot Remand When Facts Are Already on Record | Section 147/148 Income Tax Act
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order passed by the Income Tax Appellate Tribunal (ITAT), wherein the Tribunal
remanded the matter back to the Dispute Resolution Panel (DRP) f...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Cannot Remand When Facts Are Already on Record | Sections 147/148 & Permanent Establishment
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order of the Income Tax Appellate Tribunal (ITAT), which had remanded the
matter back to the Dispute Resolution Panel (DRP). The core issue rev...
Commissioner of Income Tax (Exemption) vs Indo-French Centre for Promotion of Advanced Research (Delhi High Court) – No Addition on Foreign Government Grants, FCRA Not Applicable
Facts of the CaseThe present appeal was filed by the Revenue against the order
of the Income Tax Appellate Tribunal concerning Assessment Year 2010–11. The
Tribunal had upheld the order of the Commissioner of Income ...
PR. Commissioner of Income Tax-4, Delhi vs Itochu India Pvt. Ltd. (2019) – Transfer Pricing | ALP Determination under TNMM | Section 92C & Rule 10B Analysis
Facts of the
CaseThe present appeals were filed by the Revenue
against separate orders of the Income Tax Appellate Tribunal (ITAT) for
Assessment Years 2007-08, 2008-09, and 2009-10. The assessee, Itochu India P...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Remand to DRP Held Unjustified | Permanent Establishment Issue & Sections 147/148 Analysis
Facts of the Case
The
assessee, LG Electronics Inc., Korea, was involved in multiple appeals
before the ITAT.
The
core issue revolved around the existence of a Permanent Establishment (PE)
in...
Devendra Kumar Singh vs Assistant Commissioner of Income Tax & Ors. (Delhi High Court, 2019) – Scope of Stay Order in Reassessment Proceedings under Sections 147, 148 & 143(2) of Income Tax Act
Facts of the CaseThe petitioner, Devendra Kumar Singh, filed a writ petition
challenging the reassessment notice issued under Section 148 of the Income Tax
Act for Assessment Year 2011–12. The petitioner contended th...
PR. Commissioner of Income Tax–4, Delhi vs ITOCHU India Private Limited (2019) – Delhi High Court | Transfer Pricing | ALP Determination under Rule 10B(1)(e)
Facts of the
CaseThe present appeals were filed by the Revenue
against separate orders of the Income Tax Appellate Tribunal (ITAT) for
Assessment Years 2007-08, 2008-09, and 2009-10. The Assessee, ITOCHU India P...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Remand to DRP on Permanent Establishment Set Aside
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order of the Income Tax Appellate Tribunal (ITAT), which had remanded the
matter back to the Dispute Resolution Panel (DRP).The remand was spec...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax | Delhi High Court | Remand by ITAT on Permanent Establishment & Section 147/148 – Case Law Analysis
Facts of the
CaseThe appellant, LG Electronics Inc., Korea,
challenged the order of the Income Tax Appellate Tribunal (ITAT), which had
remanded the matter back to the Dispute Resolution Panel (DRP). The core issue
r...