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Logistic Support Services, Reimbursements and Lease Line Charges Not Taxable as FTS or Royalty; Consistency Principle Applied – CIT (International Taxation)-1 vs. Expeditors International of Washington Inc. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 09.02.2024 passed by the
Income Tax Appellate Tribunal in ITA No. 2855/Del/2023 for Assessment Yea...
AMP Expenses Not an International Transaction and Section 14A Amendment Not Retrospective: Revenue Appeal Dismissed – PCIT Delhi-1 vs. Amadeus India Pvt. Ltd. (Delhi High Court)
Facts
of the CaseThe
Revenue filed an appeal under Section 260A of the Income-tax Act, 1961
challenging the order dated 10.01.2025 passed by the Income Tax Appellate
Tribunal for Assessment Year 2018–19. The Tribun...
Settlement Applications Filed Between 01.02.2021 and 31.03.2021 Held Valid; Retrospective Abolition of ITSC Cannot Defeat Vested Rights: Western UP Power Transmission Co. Ltd. vs. ITSC (Delhi HC)
Facts of the
CaseThe petitioner, Western UP Power Transmission Co.
Ltd., is a company engaged in the business of transmission and distribution of
electricity in the State of Uttar Pradesh. A search and seizure operati...
AMP Expenses Do Not Constitute International Transaction Absent Tangible Evidence: Revenue Appeal Dismissed Following Casio Precedents – PCIT-1 vs. Casio India Co. Pvt. Ltd. (Delhi High Court)
Facts
of the CaseThe
Revenue filed an appeal under Section 260A of the Income-tax Act, 1961
challenging the order dated 19.07.2022 passed by the Income Tax Appellate
Tribunal for Assessment Year 2017-18. The Tribunal...
Approval Recording “Yes, I Am Convinced It Is a Fit Case” Satisfies Section 151 Requirement: ITAT Order Set Aside – PCIT-1 vs. Agroha Fincap Ltd. (Delhi High Court)
Facts
of the CaseThe
Revenue filed an appeal under Section 260A of the Income-tax Act, 1961 against
the order dated 07.07.2023 passed by the Income Tax Appellate Tribunal for
Assessment Year 2009–10. The Assessing ...
Reassessment Order Set Aside for Non-Consideration of Assessee’s Reply on Same Transaction Already Examined: Matter Remanded under Section 148A – Michael and Susan Dell Foundation vs. DCIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Michael and Susan Dell Foundation, challenged the show cause notice
dated 31.03.2025 issued under Section 148A(1) of the Income-tax Act, 1961, the
order dated 29.06.2025 passed under ...
Section 197 Withholding Certificate Based Solely on Set-Aside Assessment Orders Unsustainable: ITAT Order on Non-Existence of DAPE Binding – Zscaler Inc. vs. DCIT (Delhi High Court)
Facts of the CaseThe petitioner, Zscaler Inc., a company incorporated in the
United States of America, is engaged in providing cloud-based software
solutions to customers in India through resellers and its Indian subsi...
Section 14A Disallowance Cannot Exceed Exempt Income; Finance Act 2022 Amendment Held Prospective – PCIT (Central)-1 vs. R.J. Corp. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 25.08.2022 passed by the
Income Tax Appellate Tribunal, whereby the Tribunal allowed the assessee�...
Foreign Exchange Gain/Loss to Be Treated as Operating Item; Exclusion of Brand-Driven and Functionally Dissimilar Comparables Upheld – PCIT-7 vs. Steria India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 17.11.2020 passed by the
Income Tax Appellate Tribunal, New Delhi, for Assessment Years 2010-11 an...
Reassessment for AY 2014–15 Quashed as Time-Barred Applying Ashish Agarwal and Rajeev Bansal: Entire Proceedings Set Aside – Manisha Agarwal vs. ITO (Delhi High Court)
Facts
of the CaseThe
petitioner, Manisha Agarwal, challenged the notice dated 08.06.2021 deemed to
be a show cause notice under Section 148A(b), the subsequent notices dated
18.05.2022, the order dated 25.07.2022 pas...