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Commissioner of Income Tax vs. M/s Fracht Forwarding & Travels Pvt. Ltd. (Delhi High Court) – Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c) and Impact of Section 271(1B) of the Income-tax Act
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High Court
challenging orders of the Income Tax Appellate Tribunal. The Tribunal had
granted relief to the assessees on the ground that proper satisf...
Commissioner of Income Tax vs. M/s Essan Remedies Ltd. – Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c) of the Income-tax Act, 1961 and Effect of Section 271(1B)
Facts of the Case
The
Income Tax Appellate Tribunal had allowed relief to the assessee primarily
on the ground relating to the absence or inadequacy of recorded
satisfaction for initiation of penalty ...
Commissioner of Income Tax vs. Mrs. Lata Chauhan – Satisfaction for Initiation of Penalty Proceedings under Section 271(1)(c) Deemed Valid After Insertion of Section 271(1B) | Delhi High Court
Facts of the CaseThe present appeal formed part of a batch of income-tax
appeals involving a common legal issue relating to initiation of penalty
proceedings under Section 271(1)(c) of the Income-tax Act.The matter had...
Commissioner of Income Tax vs. Late Shri A.R. Chadha (Through Legal Heir Sh. C.M. Chadha) – Penalty Proceedings under Section 271(1)(c) Invalid Without Recorded Satisfaction
Facts of the CaseThe Revenue filed appeals challenging the order of the Income
Tax Appellate Tribunal which had deleted penalties imposed under Section
271(1)(c) of the Income-tax Act, 1961.The assessment orders in the...
Commissioner of Income Tax v. M/s Eastern Holdings (P) Ltd. (2008) – Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c) of the Income Tax Act
Facts of the CaseA batch of appeals, including the appeal against M/s Eastern
Holdings (P) Ltd., involved a common question regarding the validity of penalty
proceedings under Section 271(1)(c) where satisfaction was a...
Anil Kumar Saha & Connected Matters vs Chief Commissioner of Income Tax, Delhi-I, New Delhi & Another | Transfer of Income Tax Cases under Section 127(2) of the Income Tax Act, 1961 – Requirement of Reasoned Order and Consideration of Assessee’s Objections
Facts of the CaseThe petitioners, comprising individuals and companies
belonging to the ATS Group, challenged an order dated 07.10.2008 passed by the
Commissioner of Income Tax, Delhi-I, New Delhi under Section 127(2) ...
Commissioner of Income Tax, Delhi-XI vs. Batra Bhatta Company (2008) – Reassessment under Sections 147 & 148 Cannot Be Initiated Merely for “Deeper Scrutiny” Without Reason to Believe Escapement of Income
Facts of the CaseThe assessee, Batra Bhatta Company, sold
agricultural land for ₹57,37,500 during March 1996 and claimed exemption under
Section 2(14) of the Income-tax Act, 1961 on the ground that the land sold was
...
Anil Kumar Saha & Connected Matters vs Chief Commissioner of Income Tax, Delhi-I, New Delhi & Another (2008) – Transfer of Income Tax Cases under Section 127(2) of the Income Tax Act Requires Reasoned Consideration of Assessee’s Objections
Facts of the CaseThe petitioners challenged an order dated 07.10.2008 passed by
the Commissioner of Income Tax, Delhi-I, New Delhi under Section 127(2) of the
Income Tax Act, 1961 whereby their assessment cases were tr...
Commissioner of Income Tax, Delhi-VIII v. M/s Atam Prakash & Sons & Om Prakash (Delhi High Court) – Whether Collaboration Agreement and Development Rights Constitute ‘Transfer’ Under Section 2(47) for Capital Gains Taxability
Facts of the CaseThe assessees, namely M/s Atam Prakash &
Sons (HUF) and Om Prakash, were co-owners of leasehold rights in
property situated at 22, Barakhamba Road, New Delhi. The property
consisted of land ...
Commissioner of Income Tax, Delhi-IV, New Delhi vs. Hotline Teletube & Components Ltd. [Delhi High Court] – Allowability of Provision for Diminution in Value of Obsolete Stock under Sections 115JB and 260A of the Income-tax Act, 1961
Facts of the CaseThe assessee, Hotline Teletube & Components
Ltd., was engaged in the business of manufacturing black-and-white television
picture tubes, glass shells, electron guns, and glass stems. For Assessment...