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Vedanta Limited vs Assistant Commissioner of Income Tax & Anr. (Delhi High Court) – Remand by ITAT Set Aside; Scope of Tribunal Powers, Section 37, 115JB & 32(1)(iia) Explained
Facts of the CaseThe assessee, Vedanta Limited, filed an appeal challenging the
order passed by the Income Tax Appellate Tribunal (ITAT) concerning Assessment
Year 2014–15. The dispute arose from multiple additions a...
Commissioner of Income Tax (International Taxation)-2 vs NetApp B.V. (Delhi High Court) – No Interest under Section 234B When Income Assessed as NIL | ITA 338/2022
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 20th September 2021 passed by the Income Tax Appellate Tribunal
(ITAT) in ITA No. 1882/Del/2017 for Assessment Year 2013–14. Th...
Deputy Director of Income Tax (Investigation) Unit–4(3) v. Xiongwei Li (2022) – Delhi High Court on Look Out Circular (LOC) in Economic Offences
Facts of the Case
The
respondent, CEO of Huawei Telecommunications (India) Company Pvt. Ltd.,
was subjected to investigation following a search and seizure action
under Section 132 of the Income Tax A...
PR. Commissioner of Income Tax-1 vs Avery Dennison (India) Pvt. Ltd. (2022) – Delhi High Court | Transfer Pricing | Section 92B & 92F | Intra-Group Services & Outstanding Receivables
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 11.10.2021 passed by the Income Tax Appellate Tribunal (ITAT) for
Assessment Year 2009–10. The dispute primarily revolved aroun...
PR. Commissioner of Income Tax-1 vs M/s Attire Designers Pvt. Ltd. (2022) – Section 68 & Section 37(1) Additions Not Sustainable When Purchases Accepted | Delhi High Court
Facts of the CaseThe Revenue filed an appeal challenging the ITAT order which
upheld the deletion of additions made by the Assessing Officer under Section 68
and Section 37(1) of the Income Tax Act.The Assessing Office...
Commissioner of Income Tax (International Taxation)-2 vs. M/s Nagravision S.A. (Delhi High Court, 2022) – No Royalty on Supply of Software under Section 9(1)(vi) & India-Switzerland DTAA
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 dispute arose regarding the...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation (2022:DHC:3803-DB) – Transponder Charges Not Taxable as Royalty under Section 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue before the
Delhi High Court challenging the orders passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2014–15 and 2015–16. The cor...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation | Delhi High Court (2022) – Transponder Charges Not Taxable as Royalty u/s 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue challenging
the orders passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Years 2014–15 and 2015–16. The dispute pertains to whether pay...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Batch Matters (Delhi High Court) – Section 153A Additions Without Incriminating Material Invalid
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging a common order of the Income Tax Appellate Tribunal (ITAT)
relating to multiple assessment years of various group companies.A search w...
PR. Commissioner of Income Tax (Central)-2 vs M/s JPM Tools Ltd. & Connected Matters | Delhi High Court | Section 153A & 68 Income Tax Act | No Addition Without Incriminating Material
Facts of the CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common ITAT order dated 23.12.2021 concerning
various assessment years (AY 2008–09 to AY 2011–12). The dispute arose fro...