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Chetan Sabharwal & Nitin Sabharwal vs Assistant Commissioner of Income Tax, Circle 28(1) – Reopening of Assessment under Sections 147/148, Change of Opinion & Investigation Report Validity | Delhi High Court (2019)
Facts of the Case
Petitioners
Chetan Sabharwal and Nitin Sabharwal sold shares of:
Pawan
Impex Pvt. Ltd.
SVIIT
Software Pvt. Ltd.
Sale
was executed through Share Purchase Agre...
Principal Commissioner of Income Tax-8 vs M/s Samsung India Electronics Pvt. Ltd. | Section 254(2A) Income Tax Act – ITAT Stay Beyond 365 Days Not Permissible
Facts of the
CaseThe present writ petitions were filed by the
Revenue (Principal Commissioner of Income Tax-8) challenging the extension of
an interim stay order granted by the Income Tax Appellate Tribunal (ITAT) in
...
Rolls-Royce Plc vs Deputy Director of Income Tax (International Taxation), New Delhi (2019) – Permanent Establishment, Section 9(1), Indo-UK DTAA
Facts of the CaseThe appellant, Rolls-Royce Plc, challenged a common order
passed by the Income Tax Appellate Tribunal (ITAT) concerning Assessment Years
2004–05 to 2009–10. The ITAT dismissed the appeals rel...
M/s Nestlé SA vs Assistant Commissioner of Income Tax (International Taxation), Circle-2(2)(2), New Delhi (Delhi High Court, 2019) – Reassessment u/s 147/148 Invalid When No Income Escaped Assessment & Return Filing Not Required u/s 115A(5)
Facts of the CaseThe Petitioner, M/s Nestlé SA, a tax resident of
Switzerland, earned income in India during AY 2011–12 in the form of dividend
and interest from its Indian subsidiary, Nestlé India Ltd. Tax was dul...
Rolls-Royce PLC vs Deputy Director of Income Tax (International Taxation) – Determination of Permanent Establishment (PE) in India under Section 9 of Income Tax Act & Indo-UK DTAA
Facts of the Case
Rolls-Royce
PLC (assessee) filed appeals against the Income Tax Appellate Tribunal
(ITAT) order for AYs 2004-05 to 2009-10.
ITAT
relied on an earlier Delhi High Court judgment (20...
PR. Commissioner of Income Tax-4, New Delhi vs Symphony Marketing Solutions India Pvt. Ltd. (Now Merged with Genpact India) – Delhi High Court | Exclusion of Infosys BPO as Comparable in Transfer Pricing
Facts of the CaseThe present matter concerns two appeals filed by the Revenue
against orders of the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2009-10 and 2010-11. The assessee, Symphony Marketing Soluti...
Principal Commissioner of Income Tax-6 vs Nalwa Sons Investment Ltd. (Delhi High Court) – Section 14A, Section 73, Section 36(1)(vii), Section 68 | Speculative Loss & Bad Debt Write-off
Facts of the
Case
The case concerns appeals filed by the Revenue under Section
260A of the Income Tax Act, 1961 against the order of the ITAT.
The assessee, Nalwa Sons Investment Ltd., functioned primar...
PR. Commissioner of Income Tax-4, New Delhi vs Symphony Marketing Solutions India Pvt. Ltd. (Now Merged with Genpact India) – Delhi High Court | Transfer Pricing | Exclusion of Infosys BPO as Comparable
Facts of the
CaseThe present matter concerns appeals filed by the
Revenue before the Delhi High Court against the orders of the Income Tax
Appellate Tribunal (ITAT) dated 4th April 2017 and 18th August 2017 for
Asses...
Rolls-Royce PLC vs Deputy Director of Income Tax (International Taxation), New Delhi | Delhi High Court | Section 9(1), Indo-UK DTAA – Permanent Establishment (PE) Determination
Facts of the CaseThe appellant, Rolls-Royce PLC, challenged a common order of
the Income Tax Appellate Tribunal (ITAT) dated 28 May 2019 concerning
Assessment Years 2004-05 to 2009-10. The Tribunal had dismissed the ap...
Rolls-Royce Plc vs Deputy Director of Income Tax (International Taxation), Delhi High Court | Permanent Establishment under Section 9(1) & Indo-UK DTAA
Facts of the CaseThe present case pertains to appeals filed by Rolls-Royce
Plc (assessee) before the Delhi High Court against a common order of the Income
Tax Appellate Tribunal (ITAT) concerning Assessment Years 2004â...