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Commissioner of Income Tax vs. Late Shri A.R. Chadha (Through Legal Heir Shri C.M. Chadha) – Satisfaction for Initiation of Penalty under Section 271(1)(c) Must Be Evident from Assessment Order
Facts of the CaseThe Revenue filed appeals challenging the order of the Income
Tax Appellate Tribunal, which had held that penalty proceedings initiated
against the assessee under Section 271(1)(c) were invalid. The as...
Commissioner of Income Tax vs. Tyagi Group (ITA No. 685/2008) – Valuation of Unquoted Equity Shares under Section 2(22B)(ii) of the Income Tax Act, 1961: Delhi High Court Upholds Principle of Consistency in Determining Fair Market Value Based on Co-Owner's Co-ordinate Valuation by DVO
Facts of the Case
The
Revenue filed six interconnected appeals against a common order passed by
the Income Tax Appellate Tribunal (ITAT) dated September 17, 2001.
The
respondents/assessees all belon...
Commissioner of Income Tax vs. M/s. [Assessee Name*]: Determining Capital Cost of Assets and Tax Treatment of Annual Maintenance Contracts (AMC)
Facts
of the CaseThe Income Tax Appellate Tribunal
(ITAT) arrived at a factual determination regarding the treatment of payments
made for an Annual Maintenance Contract (AMC). The assessee had entered into a
contract...
Commissioner of Income Tax vs. M/s Utkal Investment Ltd. – Effect of Section 271(1B) on Recording of Satisfaction for Penalty Proceedings under the Income-tax Act, 1961 | Delhi High Court
Facts of the Case
Multiple
appeals filed by the Revenue, including the appeal against M/s Utkal
Investment Ltd., involved a common substantial question of law relating to
the recording of satisfaction...
Commissioner of Income Tax vs. Tyagi Group (ITA No. 664/2008) – Scope of Section 2(22B)(ii) of Income Tax Act: Principle of Consistency Mandates Adoption of Fair Market Value of Unquoted Shares Established in Co-Owners' Case Without Re-Assessment by DVO
Facts of the Case
The
matter arose out of six interconnected appeals preferred by the Revenue
against a common order passed by the Income Tax Appellate Tribunal (ITAT)
on September 17, 2001.
The
...
Commissioner of Income Tax Vs. Tyagi Group: Delhi High Court Affirms Rule of Consistency in Determining Fair Market Value of Unquoted Equity Shares under Section 2(22B)(ii) of the Income Tax Act, 1961 – Rejection of Repetitive DVO Valuation for Co-Owners/Same Asset Class
Facts of the Case
The
six interconnected appeals arose out of a common order passed by the
Income Tax Appellate Tribunal (ITAT) on September 17, 2001, concerning
multiple assessees belonging to the "T...
Commissioner of Income Tax v. Mr. S. Venkatnarayan & Connected Matters (2008) – Effect of Section 271(1B) on Recording of Satisfaction for Penalty Proceedings
Facts of the CaseA batch of appeals filed by the Revenue came before the Delhi
High Court. The common controversy related to the validity of penalty
proceedings initiated under Section 271 of the Income Tax Act on the ...
Commissioner of Income Tax vs. Gulf Air Company: Clarifying TDS Applicability on Hotel Payments and Service Charges under Section 194-I of the Income Tax Act, 1961
· Facts
of the CaseThe respondent, Gulf Air Company, is a
non-resident airline operating flights to Mumbai and Delhi. For the assessment
year 2001-02, the Assessing Officer (AO) contended th...
Principle of Consistency in Valuation of Unquoted Shares: CIT v. Tyagi Group (2008:DHC:12410-DB) – Delhi High Court Rules on Binding Nature of DVO Reports for Co-owners under Section 2(22B)(ii) of the Income Tax Act, 1961
Facts of the Case
The
six conjoined appeals arose out of a common order passed by the Income Tax
Appellate Tribunal (ITAT) on September 17, 2001.
The
Assessees belong to the "Tyagi Group" and held ...
Commissioner of Income Tax v. M/s SRJ Securities (Now Adinath Capital Pvt. Ltd.) | Delhi High Court on Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c) of the Income Tax Act
Facts of the CaseThe Revenue filed appeals against orders passed by the Income
Tax Appellate Tribunal. The Tribunal had decided the matters primarily on the
issue that proper satisfaction for initiation of penalty proc...