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Sri Guru Singh Sabha vs Dy. Commissioner of Income Tax (Delhi High Court) – Taxability of Gross Receipts vs Income & Applicability of Maximum Marginal Rate under Section 167B and Section 143(1)
Facts of the
CaseThe appellant, Sri Guru Singh Sabha, filed
its return of income for Assessment Year 2014–15 declaring income of ₹2,39,350.
The return was processed under Section 143(1) of the Income Tax Act, 1961...
Commissioner of Income Tax (International Taxation)-1 vs Fujitsu America Inc. | Delhi High Court | Section 143(3) & 260A | DTAA Article 12 | Beneficial Ownership in FTS
Facts of the
Case
The assessee, Fujitsu America Inc., a US-based company, provided branding
and management services to its Indian affiliate.
It received approximately ₹9.87 crore during AY 2015–16.
The...
G.K. Choksi and Co. vs Principal Commissioner of Income Tax, Central-3 & Anr. & Connected Matters (Delhi High Court, 2023) – Interest on Delayed Payment of Audit Fees under Section 142(2A) of Income Tax Act
Facts of the
CaseThe petitioner, a chartered accountant firm, was
appointed as a special auditor by the Assessing Officer under Section 142(2A)
of the Income Tax Act, 1961. The firm conducted audits for three entities...
Shri Pawan Jhalani vs Assistant Commissioner of Income Tax (Delhi High Court, 2022) – Section 179 & Remedy under Section 264 of Income Tax Act
Facts of the
CaseThe petitioner, Shri Pawan Jhalani, filed a writ
petition challenging the order dated 01.05.2019 passed by the Assistant
Commissioner of Income Tax under Section 179 of the Income Tax Act, 1961. The
...
Hunger Heroes vs Commissioner of Income Tax (Exemption), Delhi – Rejection of Section 12A Registration Set Aside for Fresh Consideration (Delhi High Court 2022)
Facts of the
CaseThe petitioner, Hunger Heroes, had initially
obtained registration under Section 12A of the Income Tax Act on 18.11.2016 and
was subsequently granted provisional registration on 28.05.2021 pursuant to...
Vedanta Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court) – Reassessment Notice u/s 148 Quashed Due to Non-Application of Mind [AY 2011–12]
Facts of the
CaseThe present writ petition was filed challenging the
validity of a reassessment notice dated 28.03.2018 issued under Section 148 of
the Income Tax Act, 1961. The petitioner, Vedanta Ltd. (successor of ...
PR. Commissioner of Income Tax–9 vs M/s YKK India Private Ltd. | Delhi High Court | Remand to TPO & Rule 29 ITAT Rules | Transfer Pricing Case Law
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 22.10.2018 passed by the Income Tax Appellate
Tribunal (ITAT). The Tribunal had remitted the matter back to the Transfer
Pri...
PR. Commissioner of Income Tax–9 vs M/s YKK India Private Ltd (Delhi High Court) – Remand to TPO under Rule 29 ITAT Rules | Delay Condoned | ITA 540/2022 & Connected Appeals
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 22.10.2018 passed by the Income Tax Appellate
Tribunal (ITAT).The ITAT had remitted the matter to the Transfer
Pricing Offic...
PR. Commissioner of Income Tax–9 vs M/s YKK India Pvt. Ltd. | Delhi High Court | Remand to TPO under Rule 29 of ITAT Rules | No Prejudice to Revenue
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 22.10.2018 passed by the Income Tax Appellate
Tribunal (ITAT).The ITAT had remitted the matter back to the
Transfer Pricing ...
PR. Commissioner of Income Tax–9 vs M/s YKK India Pvt. Ltd. | Delay Condonation & Remand to TPO under Rule 29 ITAT Rules – Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 22.10.2018 passed by the Income Tax Appellate
Tribunal (ITAT). The Tribunal had remitted the matter back to the Transfer
Pri...