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Deepak Kapoor vs Principal Commissioner of Income Tax-2, New Delhi & Ors. | Delhi High Court | Reopening of Assessment u/s 147/148 on Change of Opinion – Capital Gains Dispute
Facts of the
CaseThe petitioner, Deepak Kapoor (assessee),
challenged a reassessment notice issued under Section 148 of the Income Tax
Act, 1961 for Assessment Year 2016–17. The notice alleged that income had
escap...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fee Taxability as Business Income, PE Profit Attribution @15%, and Non-Applicability of Interest u/s 234B where TDS Deductible
Facts of the CaseThe present appeals were filed by the Revenue
against a common order dated 29.01.2021 passed by the Income Tax Appellate
Tribunal concerning Assessment Years 2013-14, 2014-15, 2015-16, and 2016-17. The...
International Tractors Ltd. vs Deputy Commissioner of Income Tax (LTU) & Anr. – Section 250(4) & 80JJAA | Delhi High Court Allows Deduction, Sets Aside ITAT Remand
Facts of the
CaseThe assessee, International Tractors Ltd., filed an
appeal before the Delhi High Court challenging the order of the Income Tax
Appellate Tribunal (ITAT), which had set aside the relief granted by the
...
PR. Commissioner of Income Tax (Central)-2 vs. M/s Jay Ambey Aromatics (Delhi High Court) – Section 153A | No Addition Without Incriminating Material in Search Cases
Facts of the
Case
The Revenue filed multiple appeals challenging a common order of
the ITAT dated 15.07.2021.
The ITAT had deleted additions made by the Assessing Officer for
AYs 2008-09 to 2011-12.
...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fee Taxability, PE Profit Attribution & Section 234B Interest
Facts of the
CaseThe appeals were filed by the Revenue against a
common order passed by the Income Tax Appellate Tribunal concerning Assessment
Years 2013-14 to 2016-17. The dispute pertained to the taxability of inco...
PR. Commissioner of Income Tax (Central)-2 vs M/s Jay Ambey Aromatics (Delhi High Court) – Section 153A Additions Without Incriminating Material Not Sustainable
Facts of the
CaseThe Revenue filed multiple appeals challenging a common
order dated 15 July 2021 passed by the Income Tax Appellate Tribunal (ITAT)
relating to Assessment Years 2008-09 to 2011-12. The ITAT had delete...
PR. Commissioner of Income Tax-1 vs M/s Bechtel India Pvt. Ltd. | Delhi High Court | Transfer Pricing – Comparable Selection & Functional Dissimilarity under Section 260A
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court challenging the order of the Income Tax Appellate Tribunal
(ITAT) dated 18.12.2020 for Assessment Year 2013–14. The assessee, ...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fees Not Royalty | Section 195 & 234B | PE Profit Attribution @15%
Facts of the
CaseThe present matter concerns multiple appeals filed
by the Revenue for Assessment Years 2013–14, 2014–15, 2015–16, and 2016–17
against a common order dated 29.01.2021 passed by the Income Tax A...
PR. Commissioner of Income Tax (Central)-2 vs M/s Jay Ambey Aromatics – Section 153A Additions Without Incriminating Material Not Sustainable (Delhi High Court)
Facts of the CaseThe Revenue filed
multiple appeals before the Delhi High Court challenging a common order
passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2008-09 to 2011-12.The ITAT had
delet...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – PE Attribution, Royalty vs Business Income & Section 234B Interest
Facts of the
CaseThe appeals were filed by the Revenue against a
common order dated 29.01.2021 passed by the Income Tax Appellate Tribunal
concerning Assessment Years 2013-14 to 2016-17. The dispute revolved around th...