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Receipts from Off-the-Shelf Software, Bandwidth and IT Support Services Not Taxable as Royalty or FTS under India–Singapore DTAA; Revenue Appeals Dismissed – CIT (International Taxation) vs. DXC Technology Services Singapore (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of the Income-tax
Act challenging a common order dated 10.10.2023 passed by the Income Tax
Appellate Tribunal in respect of Assessment Years 2011-12 to 2014...
Reassessment for AY 2015–16 Quashed as Time-Barred; TOLA Inapplicable Post Rajeev Bansal – Anju Khosla vs. ITO Ward 15(1) (Delhi HC)
Facts of the CaseThe petitioner, Anju Khosla, challenged a notice dated
26.08.2024 issued under Section 148A(b) of the Income-tax Act for Assessment
Year 2015–16, the order dated 31.08.2024 passed under Section 148A(...
Reassessment Upheld Where No Change of Reasons and Section 148A Procedure Properly Followed Post-2022 Amendment – Amandeep Singh (Guru Kripa Enterprises) vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Amandeep Singh, proprietor of Guru Kripa
Enterprises, filed his return of income for Assessment Year 2021–22 on
14.03.2022 declaring income of ₹8,53,950. On 29.03.2025, the Revenue ...
Jurisdiction of Jurisdictional Assessing Officer Upheld Despite Faceless Scheme; Reassessment Notices Sustained in Delhi – All India Kataria Educational Society vs. ACIT (Delhi HC)
Facts of the CaseA batch of writ petitions, including those filed by All India
Kataria Educational Society and connected assessees, were filed before the
Delhi High Court challenging notices issued under Section 148 of...
Invalid Remand by CIT(A) Set Aside Where Jurisdictional Defect under Section 143(2) Not Adjudicated; Matter Restored to CIT(A) – Akasaki Technology (P) Ltd. vs. PCIT (Delhi HC)
Facts of the CaseThe assessee, Akasaki Technology (P) Ltd., filed its return of
income for Assessment Year 2012–13 on 28.09.2012 declaring total income of
₹48,51,840. The assessment was reopened under Section 147 o...
Draft Income Tax Rule 2026, Video Recording UNION BUDGET 2026, Memo, FAQ, Key Features & Virtual Webinar on UNION BUDGET 2026 – Comprehensive Analysis of Direct and Indirect Tax Proposals (Monday, 02 February 2026 | 5:00 PM – 7:00 PM
Draft Income Tax Rule 2026https://incometaxindia.gov.in/Documents/draft-income-tax-rules/draft-Income-tax-Rules-2026.pdf Link of Video Recordinghttps://www.youtube.com/watch?v=Za1eZR0efPkLink Finance Billhttps://myt...
Refund of Unutilised ITC Post-Amalgamation Not Permissible Without Complete ITC Transfer: Gujarat High Court in M/s Alstom Transport India Ltd. v. Additional Commissioner, CGST & CE (Appeals) | Relying on VKC Footsteps (SC)
1. Background & Factual Matrix
Three
Alstom group companies, including Alstom Rail Transportation India
Pvt. Ltd. (ARTIPL), were amalgamated into Alstom Transport India Ltd.
(ATIL) ...
GST Search and Seizure under Section 67 CGST Upheld at Investigation Stage; Allegations of Coercion, Illegal Entry and Privacy Violation Rejected – Modern Creation vs. Principal Commissioner CGST Delhi East (Delhi High Court)
Facts of the
CaseModern Creation, a partnership firm controlled by
members of the Gumber family, filed a writ petition as part of a batch of
connected matters led by Genesis Enterprises, challenging inspection, search...
Redemption Fine Held Covered Under Sabka Vishwas Scheme; Discharge Certificate Directed to Be Issued in Seizure Cases – Lokesh Pathak vs. Designated Committee SVLDRS (Delhi High Court)
Facts of the
CaseThe petitioner, Mr. Lokesh Pathak, along
with connected petitioners, was subjected to searches by the Directorate
General of Central Excise Intelligence in November 2004 at business and
residential p...
GST Department Directed to Re-Credit ITC Through Manual Intervention Where Portal Limitation Prevented Issuance of PMT-03 – Mohan Footcare Pvt. Ltd. vs. Deputy Commissioner CGST (Delhi High Court)
Facts of the
CaseThe petitioner, M/s Mohan Footcare Pvt. Ltd., filed
a writ petition seeking issuance of Form GST PMT-03 and re-credit of Input Tax
Credit amounting to ₹23,32,278. The petitioner had filed a refund c...