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Pr. Commissioner of Income Tax vs. PNB Housing Finance Ltd. (Delhi High Court) – Section 14A & 36(1)(viii) Deduction on Stock-in-Trade Income Clarified
Facts of the CaseThe assessee, PNB Housing Finance Ltd., a subsidiary of
Punjab National Bank, is engaged in retail lending and long-term housing
finance. For Assessment Year 2010–11, the Revenue challenged the ITAT�...
Mrs. Anjul vs Office of Principal Commissioner of Income Tax-12 & Ors. (Delhi High Court, 2022) – Interest on Delayed Refund under Direct Tax Vivad Se Vishwas Act
Facts of the
Case
The petitioner was granted a final certificate (Form-5)
under the VSV Act on 05 April 2021, determining refund amounts for
AY 2010-11 and 2011-12.
Despite determination, the refund was...
Principal Commissioner of Income Tax (Central-1) vs Gautam Bhalla – No Addition u/s 153A Without Incriminating Material in Non-Abated Assessments (Delhi High Court)
Facts of
the CaseThe Revenue filed an appeal challenging the order of the
Income Tax Appellate Tribunal (ITAT) dated 31 July 2020 for Assessment Year
2011-12. The ITAT had held that no addition could be made und...
The Pr. Commissioner of Income Tax-3 vs M/s Amway India Enterprises (2022:DHC:3715-DB) | Delhi High Court | Transfer Pricing & Royalty Adjustment u/s 92C of Income Tax Act
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT) for Assessment Year 2013-14. The assessee, M/s Amway India Enterprises, is engaged in
direc...
PR. Commissioner of Income Tax (Central)-02 vs Shri Krishan Lal Madhok (Delhi High Court) – Double Taxation Not Permissible on Same Income | Section 69 Income Tax Act
Facts of the
CaseThe present appeals were filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT) concerning
Assessment Years 2006-07 and 2007-08. The dispute arose from additions made u...
Zelos Developers Private Limited vs Assistant Commissioner of Income Tax Circle 25(1), Delhi (2022) – Reassessment Set Aside Due to Non-Consideration of Material Evidence under Sections 148A & 148 of Income Tax Act
Facts of the
CaseThe Petitioner challenged an order passed under
Section 148A(d) and a consequential notice issued under Section 148 for
Assessment Year 2016–17. The reassessment proceedings were initiated on the
a...
Commissioner of Income Tax (International Taxation)-2 vs. M/s Nagravision S.A. | Delhi High Court | Section 9(1)(vi) – Royalty on Software Supply Not Taxable
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 31 January 2022 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2017–18.The core issue pertained to the...
PR. Commissioner of Income Tax–7 vs M/s PTC India Financial Services Ltd (2022:DHC:3829-DB) – No Disallowance under Section 14A Where Investments Made from Own Funds | Delhi High Court
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 19.02.2021 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2010–11. The dispute arose on two key disall...
Pr. Commissioner of Income Tax-6 vs Macquarie Global Services Pvt. Ltd. (Delhi High Court) – Transfer Pricing | Exclusion of Comparables | No Substantial Question of Law
Facts of the
Case
The Assessee, Macquarie Global Services Pvt. Ltd., was
engaged in providing ITES services.
The matter relates to Assessment Year 2011–12.
The case was referred to the Transfer Pricing O...
Kamlesh Keswani vs Assistant Commissioner of Income Tax, Circle 49(1), Delhi (2022) – Reassessment u/s 148 Invalid on Change of Opinion & Section 54 LTCG Exemption Allowed on Joint Property Purchase | Delhi High Court
Facts of the
CaseThe petitioner sold a residential property located
at Defence Colony, New Delhi, for ₹2 crores and declared the same as Long Term
Capital Gain (LTCG) in his return. Subsequently, he purchased a new ...