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Labvantage Solutions Inc vs DCIT – ITAT on Taxability of Software / Technical Services Income in India under the Income-tax Act & DTAA
Facts of the CaseThe assessee, Labvantage Solutions Inc, a non-resident
company, was engaged in providing specialized software solutions and related
services to customers in India. The assessee received payments from I...
Addition under Section 153A Cannot Be Sustained Without Incriminating Material in Unabated Assessments – DCIT vs Amit Sankhwal (ITAT Delhi) | Sections 132, 133A, 153A of Income Tax Act
Facts of the CaseA search and seizure operation under Section 132 of the Income
Tax Act, 1961 was conducted on 27.07.2016 and 23.08.2016 at the premises of the
assessee and related group entities.Subsequently, assessme...
ITAT Delhi: Assessment under Section 153C Cannot Survive Without Valid Incriminating Material – DCIT vs Apple Commodities Ltd.
Facts of the CaseA search action was conducted in the case of the Apple Group
of companies, during which certain documents were seized. Based on the seized
material, the Assessing Officer initiated proceedings against ...
DCIT vs Gynia Holding Ltd. (ITAT Delhi) – Invalidity of Assessment u/s 153C for Absence of Separate Satisfaction Note and Mandatory Draft Assessment Order u/s 144C | AY 2006-07 to 2011-12
Facts of the CaseA search and seizure operation was conducted on 22.03.2012
under Section 132 of the Income Tax Act, 1961 in the case of the Focus Energy
Group. During the course of the search, certain documents allege...
Initiation of Proceedings u/s 153C Invalid Where Assessment Years Fall Beyond Permissible Six-Year Period – DCIT vs Wickwood Development Ltd (ITAT Delhi)
Facts of the CaseA search and seizure action under Section 132 of the Income
Tax Act was conducted on 22.03.2012. During the search proceedings, certain
documents were allegedly found relating to Wickwood Development L...
ITAT Delhi: Proceedings under Section 153C Invalid Without Proper Satisfaction Note – DCIT vs Rolland Enterprises Ltd.
Facts of the CaseA search and seizure operation under Section 132 of the Income
Tax Act, 1961 was conducted on 22.03.2012 in relation to certain entities.
During the course of the search, certain documents and material...
Twylight Infrastructure Pvt Ltd vs Income Tax Officer (Delhi High Court) – Reassessment Notice Quashed for Lack of Sanction by Correct Specified Authority under Section 151(ii)
Facts of the CaseThe petitioners filed their income-tax returns for Assessment Years 2016-17 and 2017-18, which
were processed under Section 143(1) of
the Income Tax Act, 1961.Later, the Income Tax Department initiated...
Twylight Infrastructure Pvt Ltd vs Income Tax Officer (Delhi High Court) – Reassessment Notices Quashed for Want of Sanction by Specified Authority under Section 151(ii)
Facts of the CaseThe petitioners had filed their income tax returns for the relevant
assessment years, which were processed under Section 143(1) of the Income Tax Act, 1961.Subsequently, the Income Tax Department initia...
Twylight Infrastructure Pvt Ltd vs Income Tax Officer (Delhi High Court) – Reassessment Notices Quashed for Want of Approval from Specified Authority under Section 151(ii)
Facts of the CaseThe petitioners filed their income-tax returns for Assessment Years 2016-17 and 2017-18, which
were processed under Section 143(1) of
the Income Tax Act, 1961.Subsequently, the Income Tax Department in...
Harshdip Singh Dhillon v. Union of India (Delhi High Court, 2024) – Assessee Cannot Be Asked to Pay Tax When TDS Already Deducted by Employer | Sections 199 & 205 Income Tax Act
Facts of the CaseThe petitioner, Harshdip Singh Dhillon, was employed as Associate Vice-President
with Tulip Telecom Ltd. from November 2011 to May 2013. During his employment,
the employer deducted Tax Deducted at
So...