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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...
G.K. Choksi and Co. vs Principal Commissioner of Income Tax (Central) & Anr. – Interest on Delayed Audit Fees under Section 142(2A) of Income Tax Act
Facts of the
CaseThe petitioner, G.K. Choksi and Co., was appointed
as an auditor by the Assessing Officer under Section 142(2A) of the Income Tax
Act, 1961. The petitioner conducted audits for three entities:
Futur...
Blackstone Capital Partners (Singapore) VI FDI Three Pte. Ltd. vs Assistant Commissioner of Income Tax (International Taxation) – Reassessment u/s 148A(d) Set Aside for Non-Application of Mind on Capital Transaction Issue
Facts of the
CaseThe petitioner, a non-resident entity, purchased
shares of an Indian company, namely Agile Electric Sub-Assembly Pvt. Ltd. The
transaction involved payment to various sellers, including a resident sel...
Subhash Bhatia HUF vs Income Tax Officer Wa3. rd-47(1), Delhi & Anr. – Delhi High Court Quashes Reassessment Proceedings under Sections 148A & 148 (AY 2017-18)
Facts of the
CaseThe petitioner, Subhash Bhatia HUF,
challenged reassessment proceedings initiated by the Income Tax Department. An
assessment order had earlier been framed under Section 147 read with
Sections 144 an...
InterGlobe Enterprises Pvt. Ltd. vs Pr. Commissioner of Income Tax Delhi-4 (2023) – Double Taxation on Interest Income & Scope of Section 264 Explained
Facts of the
CaseThe petitioner, InterGlobe Enterprises Private
Limited, filed its return for Assessment Year 2014-15, including a sum
of ₹1,51,67,868/- as interest income received on income tax refunds pertaining
...
PR. Commissioner of Income Tax-7 vs South Delhi Promoters Ltd. (Delhi High Court) – Reassessment u/s 147 Invalid Due to Change of Opinion & Lack of Failure to Disclose Material Facts
Facts of the
CaseThe assessee company received share application
money amounting to ₹16.88 crore at a premium. During the original assessment
under Section 143(3), the Assessing Officer (AO) examined the identity,
...
M/s RELX India Private Limited vs Deputy Commissioner of Income Tax Circle 78(1) Delhi & Ors. – Refund Claim, Recovery under Section 226(3) & Stay of Demand | Delhi High Court
Facts of the
CaseThe petitioner, M/s RELX India Private Limited,
filed a writ petition seeking issuance of a refund amounting to ₹6,95,43,498/-
along with applicable interest after adjusting 20% of the disputed tax ...