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Commissioner of Income Tax Delhi vs M/s Majestic Hotels Ltd. – Section 201 and Section 194A(3)(iii)(b) of the Income Tax Act – Non Deduction of Tax at Source on Interest Payments to TFCI
Facts of the CaseThe dispute arose from the assessee's failure to deduct tax
at source on payments made to Tourism Finance Corporation of India Limited
(TFCI). The assessee claimed that the payments were exempt from de...
Commissioner of Income Tax vs M/s International Audio Visual – Penalty under Section 271(1)(c) on Disallowance of Deduction under Section 80HHC
Facts of the CaseThe assessee, M/s International Audio Visual, claimed
deduction under Section 80HHC of the Income Tax Act in respect of dubbing
rights of Hindi films, which it stated had been sold to a foreign company...
Commissioner of Income Tax vs M S Muthoot M George Bankers – Rule of Consistency in Tax Litigation and Maintainability of Revenue Appeal Sections 260A of the Income Tax Act, 1961
Facts of the CaseThe Revenue filed an appeal before the Delhi High Court under
Section 260A challenging the order dated 30 September 2005 passed by the Income
Tax Appellate Tribunal, Delhi Bench 'C', relating to Assess...
Commissioner of Income Tax vs M S Muthoot M George Bankers – Rule of Consistency in Tax Litigation and Maintainability of Revenue Appeal Sections 260A of the Income Tax Act, 1961
Facts of the CaseThe Revenue filed an appeal before the Delhi High Court under
Section 260A challenging the order dated 30 September 2005 passed by the Income
Tax Appellate Tribunal, Delhi Bench 'C', relating to Assess...
Commissioner of Income Tax, Delhi vs M/s DLF Universal Ltd. – Addition of Unproved Liabilities, Admission of Additional Evidence under Rule 46A and Scope of Appeal under Section 260A of the Income Tax Act
Facts of the CaseThe assessee, M/s DLF Universal Ltd., filed its return of
income for Assessment Year 1992-93. During the assessment proceedings, the
Assessing Officer found that the assessee had failed to justify cert...
Commissioner of Income Tax, Delhi vs M S Bhiwani Synthetics Ltd. – Validity of Return Signed by General Manager and Curable Defect under Sections 140(c), 139(9) and 260A of the Income Tax Act, 1961
Facts of the CaseM S Bhiwani Synthetics Ltd. filed its return of income for
Assessment Year 1994-95 on 30 November 1994 declaring a loss. However, the
return was not signed by the Managing Director or any Director of t...
Calculation of Section 80-I Deductions: The Commissioner of Income Tax vs. M/s S.K.G. Engineering Pvt. Ltd.
Facts
of the CaseFor the assessment year 1996-97, the
assessee claimed deductions under both Section 80HH and Section 80-I of the
Income Tax Act. The Assessing Officer initially held that the deduction under
Section ...
Provision for Warranty Expenses: Allowability as Business Deduction under Section 37 of the Income Tax Act – Commissioner of Income Tax vs. M/s. Vinitec Corporation Pvt. Ltd.
Facts
of the CaseThe assessee (M/s. Vinitec Corporation
Pvt. Ltd.) filed its income tax return for the assessment year 2000-01. During
the assessment process, the assessee claimed a deduction for a provision
created ...
Commissioner of Income Tax vs. M/s HCL Info System Ltd.: Liability for TDS on Conveyance and Leave Travel Allowance
Facts
of the CaseThe assessee, M/s HCL Info System Ltd.,
engaged in the computer hardware business, was subject to a survey under Section
133A of the Income Tax Act, 1961. The Assessing Officer (AO) noted that the
co...
Commissioner of Income Tax vs. M/s. Fujitsu Ltd. Japan & Anr.: Bona Fide Belief as Reasonable Cause for Non-Deduction of TDS
Facts
of the CaseThe case involved multiple non-resident
companies, including M/s. I.H.I. Co. Ltd. and M/s. Fujitsu Ltd. Japan, which
operated liaison offices in India. Following survey operations under section
133A ...