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Rajasthan Global Securities Pvt. Ltd. vs Assistant Commissioner of Income Tax Circle 19(1), Delhi (2022) – Reassessment Notice on Non-Existent Entity Invalid under Income Tax Act
Facts of the
CaseThe petitioner, Rajasthan Global Securities Pvt.
Ltd., successor to Aureole Impex Pvt. Ltd., challenged reassessment proceedings
initiated by the Income Tax Department for Assessment Year 2013–14.
...
Commissioner of Income Tax (Exemptions), Delhi vs Mata Parvati Educational & Innovative Society – Section 12AA Registration Cannot Be Denied on Grounds of Application of Income | Delhi High Court
Facts of the CaseThe Revenue filed an appeal challenging the order
of the Income Tax Appellate Tribunal (ITAT), which directed grant of
registration under Section 12AA to the respondent society. The respondent
s...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – No Substantial Question of Law on PE Attribution, Royalty vs Business Income & Section 234B Liability
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against a common order dated 26.10.2020 passed by
the Income Tax Appellate Tribunal concerning Assessment Years 2007–08, 200...
Rajesh Katyal vs Income Tax Department, New Delhi (Delhi High Court, 2022) – Non-Retrospective Application of Benami Law | Section 53 PBPT Act
Facts of the
CaseThe petitioner challenged a Show Cause Notice dated
04 April 2022 issued under Section 53 of the Prohibition of Benami Property
Transactions Act, 1988 (as amended in 2016).The notice pertained to alle...
Inder Singh vs Income Tax Officer (Delhi High Court) – Section 68 Addition Unsustainable Without Books of Accounts | AY 2009-10
Facts of the
CaseThe present appeal was filed by the assessee (Inder
Singh) before the Delhi High Court challenging the order dated 23.08.2018
passed by the Income Tax Appellate Tribunal (ITAT), along with the subsequ...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP & Sheraton Overseas Management Corporation | Delhi High Court | Section 9(1)(vii) – Fee for Technical Services | Indo-US DTAA Article 12
Facts of the
CaseThe present appeals were filed by the Revenue
challenging a common order dated 29 April 2022 passed by the Income Tax
Appellate Tribunal (ITAT) for Assessment Year 2015–16. The dispute pertained to ...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP & Sheraton Overseas Management Corporation (Delhi High Court) – Centralized Services Not FTS under Section 9(1)(vii) & Indo-US DTAA
Facts of the
Case
The assessees, foreign entities, provided centralized services
to Indian customers, including:
Sales and marketing
Loyalty programs
Reservation services
Technological and ope...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fees Taxability, PE Profit Attribution & Section 234B Interest
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court concerning Assessment Years 2007–08, 2008–09,
2010–11, and 2011–12. The appeals arose from a common order dated 26.10....
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA – No Substantial Question of Law Where Issues Covered by Supreme Court & HC Precedents | Sections 195 & 234B | Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against a common order dated 26.10.2020 passed by
the Income Tax Appellate Tribunal concerning Assessment Years 2007-08, 2008-...
Cluster Overseas Private Limited vs Income Tax Officer Ward 6(1), Delhi (Delhi High Court, 2022) – Section 148 Notice Validity, Date of Issuance & Reassessment Proceedings
Facts of the
CaseThe Petitioner, Cluster Overseas Private Limited,
filed a writ petition challenging the legality of notices dated 31st March
2021 issued under Section 148 of the Income Tax Act, 1961 for Assessment
Y...