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Commissioner of Income Tax (International Taxation)-3 vs Starwood Hotel and Resorts Worldwide Inc. | Delhi High Court | Section 9(1)(vii) – FTS vs Included Services under Indo-US DTAA
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 29 April 2022 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2015–16. The dispute pertained to payment...
Openwave Mobility Inc. vs Deputy Commissioner of Income Tax & Anr (Delhi High Court, 2023) – Section 197 TDS Certificate | Taxability of Software License Fees | No Permanent Establishment in India
Facts of the CaseThe petitioner, Openwave Mobility Inc., a tax
resident of the United States, filed a writ petition challenging the denial of
a certificate under Section 197 of the Income Tax Act for deduction of tax a...
Principal Commissioner of Income Tax-7 vs Rishikesh Buildcon Pvt. Ltd. & Ors. | Section 275(1)(c) Limitation for Penalty u/s 271D – Delhi High Court
Facts of the
CaseThe present case involves three connected appeals
filed by the Revenue against different assessees, namely Rishikesh Buildcon
Pvt. Ltd., Rishikesh Properties Pvt. Ltd., and Rupa Promoters Pvt. Ltd., f...
Principal Commissioner of Income Tax-7 vs Rishikesh Buildcon Pvt. Ltd. & Ors. (Delhi High Court) – Limitation for Penalty u/s 271D read with Section 275(1)(c) of Income Tax Act
Facts of the CaseThe present appeals were filed by the Revenue
against a common order passed by the ITAT concerning Assessment Year 2006-07.
The Assessees were engaged in land development activities and had
...
Principal Commissioner of Income Tax-7 vs Rishikesh Buildcon Pvt. Ltd. & Ors. | Section 275(1)(c) Limitation on Penalty u/s 271D – Delhi High Court
Facts of the
Case
The Assessees (Rishikesh Buildcon Pvt. Ltd., Rishikesh Properties
Pvt. Ltd., and Rupa Promoters Pvt. Ltd.) were engaged in land development
business.
During assessment proceedings (AY ...
PR. Commissioner of Income Tax-10 vs M/s Rajat Finvest (Delhi High Court) – Bogus LTCG Allegation, Section 68 & 147 Reopening – No Addition Without Evidence
Facts of the
Case
A survey under Section 133A was conducted on 07.08.2012.
The Revenue alleged that the assessee introduced unaccounted income
in the guise of LTCG through transactions in shares of REI ...
PR. Commissioner of Income Tax-1 vs M/s AT and T Communication Services (India) Pvt. Ltd. – Interest under Section 220(2) Not Leviable on Set Aside Assessment Orders (Delhi High Court)
Facts of the
CaseThe Assessee, engaged in network design,
management, and communication services, filed its return for AY 2004–05
declaring income of ₹29.30 crore. The Assessing Officer (AO) assessed income at
â‚...
PR. Commissioner of Income Tax-10 vs M/s Rajat Finvest (Delhi High Court) – Bogus LTCG Allegation u/s 68 & Reassessment u/s 147/148 – No Addition Without Evidence | AY 2008-09 to 2010-11
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order of the Income Tax Appellate Tribunal concerning
Assessment Years 2008-09, 2009-10, and 2010-11.The Revenue alleged that the assesse...
Smt. Seema Gupta vs Income Tax Officer Ward 54(1) Delhi | Delhi High Court | Reassessment u/s 148 & 148A – Accommodation Entries & LTCG Dispute
Facts of the
CaseThe present writ petition was filed by the
Petitioner challenging the validity of the order passed under Section
148A(d) and the consequential notice issued under Section 148 of the
Income Tax Act, 1...
PR. Commissioner of Income Tax-7 vs Surya Fresh Foods Pvt. Ltd. | Section 153A & 80IB | No Addition Without Incriminating Material – Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the order dated 11 January 2022 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2009-10 and 2010-11. The Assessing Off...