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HCL Limited vs Commissioner of Income Tax, New Delhi — Taxability of Lump Sum Technology Transfer Payment under Section 9(1)(vi) & Article VIIIA of Indo-German DTAA
Facts of the CaseThe appellant, HCL Limited (formerly HCL Infosystems Ltd.), acting
as representative assessee of Apollo Domain Computers, GmbH Germany (ADC),
entered into a Technology Transfer and Technical Assistance...
Commissioner of Income Tax-IV vs Hero Honda Motors Ltd. (Now Hero MotoCorp Ltd.) — Royalty Payment for Technical Know-how Held Revenue Expenditure u/s 37(1), Not Capital Expenditure | Delhi High Court
Facts of the CaseThe assessee, Hero Honda Motors Ltd. (presently Hero MotoCorp
Ltd.), was engaged in manufacturing and selling motorcycles through a joint
venture with Honda Motor Co., Japan.Initially, the parties ente...
Commissioner of Income Tax, Delhi-XIII vs Chander Prakash Pabreja | Delhi High Court | Section 44AF, Section 68, Section 147 – Undisclosed Cash Deposits and Presumptive Taxation
Facts of the CaseThe assessee filed return for Assessment Year 2005–06 claiming
benefit under Section 44AF and disclosed income of ₹2,15,292. Subsequently, the
assessment was reopened under Section 147. Due to non-...
Commissioner of Income Tax-III vs Dimension Apparels Pvt. Ltd. | Delhi High Court | Section 68 & Bogus Share Capital Addition | ITA 328/2014, 329/2014, 330/2014 & 332/2014
Facts of the CaseThe Revenue challenged the order passed in favour
of the assessee company, Dimension Apparels Pvt. Ltd., regarding additions made
by the Assessing Officer under Section 68 of the Income Tax Act.The dis...
Commissioner of Income Tax-III vs Dimension Apparels Pvt. Ltd. | Delhi High Court on Dismissal of Revenue Appeals Following Earlier Coordinate Bench Judgment | Sections 260A & 10A of the Income Tax Act
Facts of the CaseThe Revenue preferred multiple income tax appeals
before the Delhi High Court against Dimension Apparels Pvt. Ltd. challenging
the order passed by the appellate authority in relation to deduction claim...
Commissioner of Income Tax-III vs. Dimension Apparels Pvt. Ltd. | Assessment on Amalgamated Company Held Void u/s 143(3), 153A, 153C & 292B of Income Tax Act – Delhi High Court
Facts of the CaseThe Revenue challenged the order passed by the
Income Tax Appellate Tribunal (ITAT), Delhi, whereby the assessment framed
against Dimension Apparels Pvt. Ltd. under Sections 143(3), 153A and 153C of
t...
PGS Geophysical AS vs Additional Director of Income Tax – Taxability of Fees for Technical Services under Sections 44BB, 44DA & 115A of the Income Tax Act | Delhi High Court
Facts of the CasePGS Geophysical AS, a company incorporated in
Norway, was engaged globally in providing geophysical and seismic survey
services including acquisition and processing of 2D and 3D seismic data for ...
Commissioner of Income Tax vs. Rachna Agarwal – Addition under Sections 69 & 69B Cannot Be Made Merely on Suspicion Without Evidence of Undervaluation | Delhi High Court
Facts of the Case
A search and seizure operation under Section 132 was conducted in
respect of the Gopal Zarda Group, including the assessee.
Proceedings under Section 153A were initiated against the assessee....
Commissioner of Income Tax vs. Rachna Agarwal – Addition under Sections 69 & 69B Cannot Be Made Merely on Suspicion Without Evidence of Undervaluation | Delhi High Court
Facts of the Case
A search and seizure operation under Section 132 was conducted in
respect of the Gopal Zarda Group, including the assessee.
Proceedings under Section 153A were initiated against the assessee....
Commissioner of Income Tax vs Heartland Delhi Transcription Services Pvt. Ltd. – Deduction Under Section 10B Cannot Be Denied on Transfer of Eligible Undertaking | Delhi High Court
Facts of the
CaseThe respondent assessee, Heartland Delhi
Transcription Services Pvt. Ltd., was incorporated on 2 August 2000 and was
engaged in export of digitized medical transcription services. The assessee
acquir...