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M/s GS1 India vs. Director General of Income Tax (Exemption) – Section 2(15) & Section 10(23C)(iv) of the Income-tax Act | Charitable Institution vs Commercial Activity Test
Facts of the CaseThe petitioner, M/s GS1 India, was a not-for-profit
society promoted by the Ministry of Commerce and Industry along with several
trade and governmental organizations. The society was established ...
Commissioner of Income Tax-II, New Delhi vs. Mira Exim Ltd. – Depreciation on Imported Cars Acquired Through Amalgamation under Section 32(1) of the Income Tax Act
Facts of the CaseMira Exim Ltd., a public limited company engaged in the
business of manufacturing and trading of readymade garments and accessories,
underwent a scheme of arrangement and amalgamation sanctioned by the...
Supreme Court on Reassessment under Sections 147 & 148 of Income Tax Act: Mere Change of Opinion Cannot Justify Reopening – Analysis of Sanand Properties Pvt. Ltd. v. Joint Commissioner of Income Tax
Facts of the CaseThe assessee, Sanand Properties
Pvt. Ltd. (“SPPL”), entered into an Agreement dated 29.04.2003 with M/s Raviraj
Kothari & Co. for constituting an Association of Persons (AOP) known as
“Forta...
Commissioner of Income Tax vs Renu Verma | Section 158BD Notice Validity, Satisfaction Note & Limitation in Block Assessment | Delhi High Court
Facts of the CaseA search operation under Section 132 was conducted at the premises
of M/s Friends Portfolio Pvt. Ltd. and its Director. During investigation, it
was alleged that accommodation entries were provid...
Director of Income Tax (International Taxation) vs GE Packaged Power Inc. & Connected Matters | Delhi High Court on Permanent Establishment, International Taxation & Attribution of Income | Sections 9 & 44BB of Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against multiple foreign GE group companies operating
through various international transactions involving Indian entities....
Director of Income Tax (International Taxation) vs GE Packaged Power Inc. & Connected Matters | Delhi High Court on Permanent Establishment, International Taxation & Attribution of Income | Sections 9 & 44BB of Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against multiple foreign GE group companies operating
through various international transactions involving Indian entities....
St. Stephen’s Hospital Society vs Deputy Commissioner of Income Tax | Delhi High Court on Section 197 TDS Certificate for Charitable Trusts under Rule 28AB
Facts of the Case
The
petitioner, St. Stephen’s Hospital Society, is a charitable institution claiming
exemption under Sections 11, 12 and 10(23C)(vi) of the Income-tax Act,
1961.
The
petiti...
Director of Income Tax vs Qualcomm Incorporated New Delhi – Delhi High Court Dismisses Revenue Appeals as Non-Maintainable Under Section 254(2) of Income Tax Act | ITA 6/2015 to ITA 10/2015
Facts of the CaseThe Revenue filed five appeals before the Delhi High Court
challenging the order dated 28.04.2014 passed by the Income Tax Appellate
Tribunal (ITAT). The impugned order was passed on an application mov...
Commissioner of Income Tax-II vs Lalit Kumar Poddar | Delhi High Court | Section 68 & Section 73(1) | Intraday Share Trading Loss and Unsecured Loan Addition Case
Facts of the CaseThe assessee was engaged in the business of trading in
stocks and shares and also acted as a sub-broker. During Assessment Year
2007-08, the assessee claimed a loss of ₹66,35,210 on account of “cle...
Commissioner of Income Tax-15 vs M/s Relcom | Delhi High Court | Section 199 TDS Credit Allowed Despite PAN Error in TDS Certificate | AY 2009-10
Facts of the
CaseThe assessee,
M/s Relcom, was engaged in the business of erection, commissioning, and
installation of towers on contract basis. For Assessment Year 2009-10, the
assessee filed its return of income wh...