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No Disallowance under Section 14A Where No Exempt Income Earned; Section 263 Cannot Be Invoked on a Plausible View – Revenue Appeal Dismissed – PCIT (Central)-2 vs. Hindustan Power Projects Pvt. Ltd. (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the common
order dated 31.12.2024 passed by the Income Tax Appellate Tribunal in ITA Nos.
2747/Del/2024 and 2748...
Section 153C Proceedings Invalid Without Year-Specific Incriminating Material; Notices for AYs 2015–16 to 2020–21 Quashed – Neeraj Bharadwaj vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Neeraj Bharadwaj, challenged multiple notices dated 24.06.2024 issued under
Section 153C of the Income-tax Act, 1961 for Assessment Years 2015–16 to
2020–21. The notices were issu...
Search-Based Reassessment for AY 2014–15 Barred by Limitation; Ten-Year Block under Section 153A Computed from AY of Search – Notice under Section 148 Quashed – N S Associates Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner, N
S Associates Private Limited, filed a writ petition challenging the notice
dated 04.02.2025 issued under Section 148 of the Income-tax Act, 1961 for
Assessment Year 2014–15 and th...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year: Search-Based Reopening Quashed – Mirza Qamarul Hasan Beg vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Mirza Qamarul Hasan Beg, filed a writ petition challenging the notice dated
22.03.2025 issued under Section 148 of the Income-tax Act, 1961 for Assessment
Year 2014–15 and the proce...
Unsecured Loan Treated as Unexplained Credit Where Identity and Creditworthiness of Lender Not Established; No Substantial Question of Law – Meenakshi Gupta vs. ITO (Delhi High Court)
Facts of the
CaseThe assessee,
Meenakshi Gupta, filed an appeal under Section 260A of the Income-tax Act, 1961
challenging the order dated 06.01.2025 passed by the Income Tax Appellate
Tribunal for Assessment Year 20...
Reassessment for AY 2014–15 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO to Decide Limitation Afresh – Manish Gupta vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Manish Gupta, filed a writ petition challenging the order dated 20.07.2022
passed under Section 148A(d) of the Income-tax Act, 1961 and the consequential
notice dated 20.07.2022 issue...
Reassessment for AY 2013–14 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO for Fresh Decision on Limitation – Dhurav Real Estate Developers Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Dhurav Real Estate Developers Private Limited, filed a writ petition
challenging the order dated 28.07.2022 passed under Section 148A(d) of the
Income-tax Act, 1961 and the consequent...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year: Search-Based Reopening Quashed – Davander Rawat vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Davander Rawat, filed a writ petition challenging the notice dated 26.03.2025
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2014–15 and all proceedings in...
Compensation and Interest Received under Arbitral Award for Offshore Supplies Constitute Business Income; Not Taxable in Absence of PE under India–Japan DTAA – CIT (IT)-1 vs. Fujitsu Limited (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the order
dated 14.11.2024 passed by the Income Tax Appellate Tribunal in ITA No.
2607/Del/2022 for Assessment Y...
Reassessment Notices for AY 2015–16 Issued After 01.04.2021 Are Time-Barred; TOLA Inapplicable – Following Rajeev Bansal – Banyan Capital Advisors LLP vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Banyan Capital Advisors LLP, filed a writ petition challenging the original
notice dated 30.06.2021 issued under Section 148, the subsequent order dated
30.06.2022 passed under Sectio...