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Usha Rani Girdhar vs Income Tax Officer Ward 36(1), Delhi & Ors. (2022) – Reassessment Notice u/s 148 & 148A Quashed Due to Contradictory Grounds and Lack of Proper Allegation
Facts of the
CaseThe petitioner challenged multiple reassessment
proceedings initiated by the Income Tax Department for Assessment Year
2017–18, including:
Notice under Section 148 dated 25 June 2021
Notice und...
PR. Commissioner of Income Tax-7 vs PEC Ltd. & RITES Ltd. | CSR Expenditure Allowability under Section 37 of Income Tax Act (Delhi High Court)
Facts of the
Case
The respondents/assessees (PEC Ltd. and RITES Ltd.) incurred CSR
expenditure during Assessment Years 2013-14 and 2014-15.
The Assessing Officer disallowed the CSR expenses claimed as
d...
PR. Commissioner of Income Tax–7 vs PEC Ltd. & RITES Ltd. | CSR Expenditure Allowable u/s 37 Prior to AY 2015-16 | Delhi High Court
Facts of the CaseThe
respondents/assessees, namely PEC Ltd. and RITES Ltd., claimed deduction of
expenditure incurred towards Corporate Social Responsibility (CSR) under
Section 37(1) of the Income Tax Act for Assessm...
PR. Commissioner of Income Tax–7 vs PEC Ltd. & RITES Ltd. | CSR Expenditure Deduction under Section 37(1) Allowed for Pre-2015 Years (Delhi High Court)
Facts of the
Case
The appeals were filed by the Revenue against orders of the Income
Tax Appellate Tribunal.
The respondents (PEC Ltd. and RITES Ltd.) claimed deduction of CSR
expenditure for AY 2013–...
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...