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Compounding Charges at 5% Not Applicable Where Earlier Compounding Application Was Rejected: CBDT Guidelines Interpreted – Sangeet Seth vs. CCIT (Delhi High Court)
Facts of the CaseThe petitioner, Sangeet Seth, approached the Delhi
High Court seeking directions to the Chief Commissioner of Income Tax to pass a
compounding order under Section 279(2) of the Income-tax Act, 1961 in ...
Jurisdictional AO and Faceless AO Have Concurrent Power to Initiate Reassessment under Section 148: TKS Builders Reaffirmed Despite Dismissal of SLPs – Rhiti Talent Management Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Rhiti Talent Management Private
Limited, filed a writ petition as part of a batch of connected matters
challenging reassessment proceedings initiated under Section 148 of the
Income-ta...
Search of Multiple Bank Lockers under Section 132 Valid Where Bona Fide Reasons to Believe Exist; CBDT Instruction No. 1916 Not Absolute – Raj Krishan Gupta & Ors. vs. PDIT (Investigation) (Delhi High Court)
Facts of the CaseThe petitioners, members of the same family, filed
a writ petition seeking a declaration that the search and seizure conducted on
11.05.2024 under Section 132 of the Income-tax Act, 1961 on three bank ...
Reassessment Valid Where Risk Management Information Indicates Bogus Purchases and AO Applies Mind under Section 148A: No Interference in Writ Jurisdiction – R S Alloys vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, R S Alloys, a partnership firm
engaged in trading of ferrous and non-ferrous metals, filed its return of
income for Assessment Year 2019–20 under Section 139(1) of the Income-tax Act,...
Disallowance under Section 40(a)(i) Barred by Non-Discrimination Clause under DTAA; No TDS Obligation Where Income Not Chargeable to Tax: Revenue Appeal Dismissed – PCIT-04 vs. Mitsubishi Corporation (India) Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 12.08.2022 passed by the
Income Tax Appellate Tribunal in ITA No. 9364/Del/2019 for Assessment Yea...
Interest on FDRs Earned from Project-Linked Funds Is Capital Receipt and Not Income from Other Sources: Revenue Appeal Dismissed – PCIT-1 vs. Brahma Center Development Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 17.07.2023 passed by the
Income Tax Appellate Tribunal, Delhi Bench, allowing the appeal of the
a...
AMP Expenses Not an International Transaction; Bright Line Test Impermissible; Revenue Appeals Dismissed – PCIT-1 vs. Casio India Co. Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of
the Income-tax Act, 1961 challenging the common order dated 24.02.2020 passed
by the Income Tax Appellate Tribunal, Delhi Bench, deciding ITA Nos.
385/D...
ITAT Justified in Remanding Subsidy Taxability Pending Supreme Court Decision; After-Sales Provision Allowable on Scientific Basis – PCIT Noida vs. Triveni Engineering (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 29.01.2025 passed by the
Income Tax Appellate Tribunal, which disposed of twelve appeals relating ...
No Depreciation Disallowance on Discarded Assets within Block; AMP Adjustment Unsustainable; Revenue Appeal Dismissed – PCIT-7 vs. Sony India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 30.08.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2010-11. The Tribunal h...
Jurisdictional Assessing Officer Competent to Initiate Reassessment Despite Faceless Scheme; Writ Dismissed Following TKS Builders – Neena Wadhwa vs. PCIT (Delhi HC)
Facts of the CaseThe petitioner, Neena Wadhwa, filed a writ
petition challenging the notice dated 20.03.2024 issued under Section 148A(b)
of the Income-tax Act, 1961, the approval dated 30.03.2024 granted under
Sectio...