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Akums Drugs and Pharmaceuticals Limited vs Deputy Commissioner of Income Tax, Delhi-1 – Reassessment u/s 147/148 Invalid due to Change of Opinion & Audit Objection (Delhi High Court)
Facts of the
CaseThe petitioner, Akums Drugs and Pharmaceuticals
Limited, filed its return of income for AY 2011-12, which was subjected to
scrutiny assessment under Section 143(3). During scrutiny, the Assessing
Off...
PR. Commissioner of Income Tax-1, Delhi vs Future First Info. Services Pvt. Ltd. – Transfer Pricing, ALP Adjustment & Comparable Selection under Section 260A of Income Tax Act
Facts of the
CaseThe assessee, Future First Info. Services Pvt.
Ltd., a subsidiary of a Mauritius-based entity, was engaged in providing IT-enabled
services (ITeS) to its associated enterprise.The assessee filed its r...
TUF Metallurgical Pvt. Ltd. & Anr. vs Union of India & Anr. – Delhi High Court on Extinguishment of Pre-CIRP Income Tax Liabilities under Section 31 IB
Facts of the
CaseThe petitions challenged income tax demands raised
after approval of resolution plans under the Insolvency and Bankruptcy Code.
In one case, the petitioner took over a corporate debtor pursuant
...
Commissioner of Income Tax, Central-III, Delhi vs Income Tax Settlement Commission & Anr. (Delhi High Court, 2023) – Effect of Section 14 IBC Moratorium on Tax Proceedings
Facts of the
CaseThe petitioner, Commissioner of Income Tax,
Central-III, Delhi, filed a writ petition against the Income Tax
Settlement Commission & Anr.
The respondent company (Respondent No. 2) was undergoing...
Commissioner of Income Tax (International Taxation)-3 vs Travelport Global Distribution Systems B.V. (Delhi High Court, ITA 748/2023, AY 2015–16)
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the order dated 27.09.2022 passed by the Income
Tax Appellate Tribunal (ITAT) for Assessment Year 2015–16.The core dis...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Hersh Washesher Chadha (Delhi High Court) – Section 69A & Section 260A Case Law on Unexplained Money and Scope of Appeal
Facts of the
CaseThe present appeal was filed by the Revenue under
Section 260A of the Income Tax Act against the order of the Income Tax
Appellate Tribunal (ITAT) for Assessment Year 2017–18.The assessee, a Non-Res...
PR. Commissioner of Income Tax–8 vs M/s Sony India Pvt. Ltd. (Delhi High Court) – AMP Expenses, Transfer Pricing Adjustment & Bright Line Test under Sections 92C & 92CA of the Income-tax Act, 1961
Facts of the CaseThe present case pertains to Assessment Year 2007–08, where
the Revenue challenged the order of the Income Tax Appellate Tribunal.The respondent/assessee, M/s Sony India Pvt. Ltd., a wholly
owned sub...
Shyam Sunder Jindal vs Assistant Commissioner of Income Tax – Delhi High Court (Section 153A) | Addition Without Incriminating Material Held Invalid
Facts of the CaseThe appellant/assessee was subjected to a search operation
conducted on 14.11.2011 under Section 132 of the Income-tax Act. Subsequently,
assessment proceedings were initiated under Section 153A for As...
AKUM DRUGS AND PHARMACEUTICALS LIMITED vs DEPUTY COMMISSIONER OF INCOME TAX, DELHI-1 – Reassessment under Section 148 quashed due to Change of Opinion and Lack of Independent Application of Mind
Facts of the
CaseThe petitioner filed its Return of Income for AY
2011–12, which was selected for scrutiny. During assessment proceedings,
detailed queries were raised, including those related to deduction claimed
...
PR. Commissioner of Income Tax (Central)-2 vs Versatile Polytech Pvt. Ltd. – Delay of 3 Years Not Condoned under Section 260A of Income Tax Act | Delhi High Court
Facts of the
CaseThe Revenue filed appeals against a common order
dated 15.03.2019 passed by the Income Tax Appellate Tribunal relating to
Assessment Years 2009–10 and 2014–15.The certified copy of the ITAT order ...