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PR. Commissioner of Income Tax-01 vs M/s C.S. Leasing Pvt. Ltd. (Delhi High Court) – Section 153C Invalid Without Proper Satisfaction Note | ITA 492/2022
Facts of the
CaseA search and seizure operation under Section 132 of
the Income Tax Act, 1961 was conducted on 28.10.2010 in the case of the Satya
Prakash & Brothers Group (SPG Group). During the course of proceed...
Pr. Commissioner of Income Tax (Central-3) vs Montage Enterprises Pvt. Ltd. | Section 80-IB Deduction on Royalty Allocation | Delhi High Court
Facts of the
CaseThe appeals were filed by the Revenue against a
common order of the Income Tax Appellate Tribunal dated 29.06.2018 concerning
Assessment Years 2008–09 and 2009–10.The dispute arose from the reallo...
Pr. Commissioner of Income Tax (Central-3) vs Montage Enterprises Pvt. Ltd. – Section 80-IB Deduction & Royalty Allocation Dispute (Delhi High Court, 2022)
Facts of the
CaseThe Revenue filed appeals against a common order
passed by the Income Tax Appellate Tribunal concerning Assessment Years 2008-09
and 2009-10. The dispute arose regarding the reallocation of royalty-re...
Commissioner of Income Tax (International Taxation)-2 vs M/s Nokia Solutions and Networks OY | Delhi High Court | No Profit Attribution to PE in Case of Global Loss under Article 7 of India-Finland DTAA
Facts of the
CaseThe Revenue filed an appeal against the order of
the Income Tax Appellate Tribunal (ITAT) dated 07.12.2021. The dispute
pertained to whether the respondent-assessee, a foreign company, had a
Permanen...
Principal Commissioner of Income Tax, Delhi-4 vs M/s MMTC Ltd. – Section 14A Disallowance Not Applicable in Absence of Exempt Income | Delhi High Court
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 29.09.2021 passed by the Income Tax Appellate
Tribunal for Assessment Year 2010–11.The core issue arose from the Tribunal’s ...
ADM Agro Industries Private Limited vs Deputy Commissioner of Income Tax Circle 1-1, Delhi (Delhi High Court) – Reassessment Notice u/s 148 & 148A(d) Set Aside for Non-Application of Mind [2022/DHC/005868]
Facts of the
CaseThe present writ petition was filed by the
Petitioner challenging:
Notice dated 26.05.2022 issued under Section 148A(b) of the
Income Tax Act, 1961
Order dated 23.07.2022 passed under Sectio...
PR. Commissioner of Income Tax-12 vs Smt. Bindu Garg (Delhi High Court) – Penny Stock LTCG Addition u/s 68 Deleted due to Lack of Independent Inquiry
Facts of the
Case
The assessee, Smt. Bindu Garg, purchased shares of two companies
and later sold them, earning long-term capital gains of ₹39,78,101.
The Revenue alleged that the transactions were bogus pe...
Empire Trading Company vs Income Tax Officer Ward 29(1) (Delhi High Court) – Reassessment Proceedings Set Aside for Non-Supply of Material under Sections 148, 148A(b), 148A(d) of Income Tax Act
Facts of the
CaseThe petitioner, Empire Trading Company, challenged
reassessment proceedings initiated by the Income Tax Department alleging that
the petitioner was a beneficiary of accommodation entries amounting to ...
PR. Commissioner of Income Tax-8 vs Prabhu Dayal Aggarwal (Delhi High Court) – Reopening u/s 147 Beyond 4 Years Invalid Without Failure to Disclose Material Facts | AY 2009-10
Facts of the
CaseThe present case pertains to Assessment Year
2009–10, where the assessee, Prabhu Dayal Aggarwal, filed his return declaring
total income of ₹1.16 crore. The assessment was completed under Section ...
Sri Guru Singh Sabha vs Deputy Commissioner of Income Tax (Delhi High Court) – Taxability of Gross Receipts vs Surplus & Applicability of Section 167B and Section 143(1) of Income Tax Act
Facts of the CaseThe assessee, a
society registered under the Societies Registration Act, filed its return
declaring income of ₹2,39,350. The return was processed under Section 143(1),
wherein the Centralized Proces...