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PR. Commissioner of Income Tax (Central)-3 vs M/s PGF Ltd. (Delhi High Court) – Section 153A Assessment Without Incriminating Material Not Sustainable (2022)
Facts of the
CaseThe present appeals were filed by the Revenue
challenging a consolidated order passed by the Income Tax Appellate Tribunal
(ITAT) for Assessment Years 2000–01 to 2003–04.A search under Section 132...
PR. Commissioner of Income Tax (Central)-2 vs M/s Bharat Hotels Ltd. – No Disallowance under Section 14A in Absence of Exempt Income (Delhi High Court)
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 30.08.2022 passed by the Income Tax Appellate
Tribunal. The matter pertains to Assessment Year 2015–16.The core issue arose fr...
PR. Commissioner of Income Tax (Central)-3 vs M/s PGF Ltd. – Section 153A Assessment Without Incriminating Material Held Invalid (Delhi High Court)
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the consolidated order of the Income Tax Appellate Tribunal (ITAT),
which upheld the order of the Commissioner of Income Tax (Appeals) quashin...
Movish Realtech Private Limited vs Deputy Commissioner of Income Tax (Delhi High Court, 2023) – Reassessment u/s 148 & 148A Set Aside for Violation of Natural Justice
Facts of the
CaseThe petitioner, Movish Realtech Private Limited
(formerly Ashiana Realtech Pvt. Ltd.), filed a writ petition challenging the
order dated 22.03.2023 passed under Section 148A(d) of the Income Tax Act, ...
PR. Commissioner of Income Tax (Central)-3 vs. M/s PGF Ltd. (Delhi High Court) – Section 153A Assessment Without Incriminating Material – Validity of Additions in Unabated Assessments
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the consolidated order of the Income Tax Appellate Tribunal (ITAT),
which upheld the decision of the Commissioner of Income Tax (Appeals) quas...
PR. Commissioner of Income Tax (Central)-3 vs. M/s PGF Ltd. (Delhi High Court) – Section 153A Assessment Without Incriminating Material – Validity of Additions in Unabated Assessments
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the consolidated order of the Income Tax Appellate Tribunal (ITAT),
which upheld the decision of the Commissioner of Income Tax (Appeals) quas...
Rahul Anand vs Assistant Commissioner of Income Tax (International Tax), Delhi – Delhi High Court Sets Aside Section 148A(d) Order Due to Violation of Natural Justice (2023)
Facts of the
CaseThe petitioner challenged the order dated
13.04.2023 passed under Section 148A(d) of the Income Tax Act, 1961, along with
the consequential notice dated 14.04.2023 issued under Section 148. The petiti...
Commissioner of Income Tax (International Taxation)-1 vs Bellsea Ltd. – No Permanent Establishment under Article 5(2)(g) of India-Cyprus DTAA due to Non-Exceeding 12-Month Threshold (Delhi High Court)
Facts of the
Case
The Respondent, Bellsea Ltd., was engaged in installation-related
activities in India.
The Revenue challenged ITAT orders for AY 2008-09 and 2009-10.
The Revenue argued that activities be...
Commissioner of Income Tax (International Taxation)-1 vs Bellsea Ltd. | Delhi High Court | Permanent Establishment under Article 5(2)(g) India-Cyprus DTAA | AY 2008-09 & 2009-10
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the orders of the Income Tax Appellate Tribunal (ITAT) for
Assessment Years 2008-09 and 2009-10. The core issue revolved around whether
the r...
Vidisha Singhal vs Income Tax Officer Ward 29(1) Delhi & Ors – Delhi High Court Sets Aside Defective Reassessment Proceedings under Sections 148, 148A(b) & 148A(d) of Income Tax Act, 1961
Facts of the
Case
Notice issued under Section 148A(b) dated 29 May 2022
Order passed under Section 148A(d) dated 22 July 2022
Consequential notice issued under Section 148 dated 23 July
2022
The petition...