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Supreme Court on Reassessment under Sections 147 & 148 of Income Tax Act: Mere Change of Opinion Cannot Justify Reopening – Analysis of Sanand Properties Pvt. Ltd. v. Joint Commissioner of Income Tax
Facts of the CaseThe assessee, Sanand Properties
Pvt. Ltd. (“SPPL”), entered into an Agreement dated 29.04.2003 with M/s Raviraj
Kothari & Co. for constituting an Association of Persons (AOP) known as
“Forta...
Commissioner of Income Tax vs Renu Verma | Section 158BD Notice Validity, Satisfaction Note & Limitation in Block Assessment | Delhi High Court
Facts of the CaseA search operation under Section 132 was conducted at the premises
of M/s Friends Portfolio Pvt. Ltd. and its Director. During investigation, it
was alleged that accommodation entries were provid...
Director of Income Tax (International Taxation) vs GE Packaged Power Inc. & Connected Matters | Delhi High Court on Permanent Establishment, International Taxation & Attribution of Income | Sections 9 & 44BB of Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against multiple foreign GE group companies operating
through various international transactions involving Indian entities....
Director of Income Tax (International Taxation) vs GE Packaged Power Inc. & Connected Matters | Delhi High Court on Permanent Establishment, International Taxation & Attribution of Income | Sections 9 & 44BB of Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against multiple foreign GE group companies operating
through various international transactions involving Indian entities....
St. Stephen’s Hospital Society vs Deputy Commissioner of Income Tax | Delhi High Court on Section 197 TDS Certificate for Charitable Trusts under Rule 28AB
Facts of the Case
The
petitioner, St. Stephen’s Hospital Society, is a charitable institution claiming
exemption under Sections 11, 12 and 10(23C)(vi) of the Income-tax Act,
1961.
The
petiti...
Director of Income Tax vs Qualcomm Incorporated New Delhi – Delhi High Court Dismisses Revenue Appeals as Non-Maintainable Under Section 254(2) of Income Tax Act | ITA 6/2015 to ITA 10/2015
Facts of the CaseThe Revenue filed five appeals before the Delhi High Court
challenging the order dated 28.04.2014 passed by the Income Tax Appellate
Tribunal (ITAT). The impugned order was passed on an application mov...
Commissioner of Income Tax-II vs Lalit Kumar Poddar | Delhi High Court | Section 68 & Section 73(1) | Intraday Share Trading Loss and Unsecured Loan Addition Case
Facts of the CaseThe assessee was engaged in the business of trading in
stocks and shares and also acted as a sub-broker. During Assessment Year
2007-08, the assessee claimed a loss of ₹66,35,210 on account of “cle...
Commissioner of Income Tax-15 vs M/s Relcom | Delhi High Court | Section 199 TDS Credit Allowed Despite PAN Error in TDS Certificate | AY 2009-10
Facts of the
CaseThe assessee,
M/s Relcom, was engaged in the business of erection, commissioning, and
installation of towers on contract basis. For Assessment Year 2009-10, the
assessee filed its return of income wh...
Commissioner of Income Tax vs. M/s Kelvinator of India Ltd. (Now Whirlpool India Ltd.) | Section 32AB & Section 80-I Deduction on Eligible Business Profits | Delhi High Court
Facts of the CaseThe Revenue filed appeals under Section 260A of the Income
Tax Act against the order of the Income Tax Appellate Tribunal concerning
Assessment Years 1989-90 and 1990-91 in the case of M/s Kelvinator o...
Commissioner of Income Tax-VIII vs. Ms. Kiran Kapoor | ITA Nos. 13/2015 to 15/2015 | Section 10B - Manufacture of Software and Data Processing
Facts of the Case:Ms.
Kiran Kapoor, an individual, filed for exemption under Section 10B of the
Income Tax Act claiming software export profits amounting to ₹39,32,654 for the
Assessment Years (AY) 2003-04 to 2006-0...