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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...
Reassessment Proceedings Quashed for Review of Section 148A(d) Order and Limitation Breach: AO Has No Power of Review – Baba Global Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Baba Global Ltd., filed a writ petition challenging the notice dated 31.03.2023
issued under Section 148A(b) of the Income-tax Act, 1961, a corrigendum dated
28.04.2023, the order dat...
Section 148 and 148A Proceedings Set Aside and Matter Remanded for Fresh Consideration in Light of Rajeev Bansal: B.C. Enterprises vs. ITO, Ward-58(3) (Delhi HC)
Facts of the
CaseThe petitioner,
B.C. Enterprises, filed a writ petition challenging reassessment proceedings
initiated for Assessment Year 2014-15. The petitioner assailed the initial
notice dated 07.06.2021 issued ...
Section 148 Notice Quashed as Time-Barred Where Ten-Year Block under Section 153A Excluded AY 2014-15: Aryan Residency Ltd. vs. ACIT, Central Circle-16 (Delhi HC)
Facts of the
CaseThe petitioner,
Aryan Residency Limited, challenged a notice dated 12.03.2025 issued under
Section 148 of the Income-tax Act for Assessment Year 2014-15. The impugned
proceedings were initiated pursu...
Criminal Prosecution under Sections 276C, 276D and 277 Quashed Where Assessment Based on Unauthenticated DTAA Information Was Set Aside: Anurag Dalmia vs. Income Tax Office (Delhi HC)
Facts of the
CaseThe petitioner,
Anurag Dalmia, filed his income tax returns for Assessment Years 2006-07 and
2007-08 declaring his income, which were accepted under Section 143(1) and
refunds were issued. In 2011, t...
Remand Proceedings Held Time-Barred for Failure to Pass Fresh Assessment within Limitation; Refund with Interest Directed: Acuity KP Solutions (India) Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the
CaseThe petitioner,
Acuity KP Solutions (India) Private Limited, filed its return of income for
Assessment Year 2007-08 declaring Nil income and claimed a refund of
₹67,86,402. The return was selected ...
Whether difference between turnover reflected in CBEC / Service Tax data and turnover recorded in the books of account can, by itself, justify an addition for under-reported revenue without independent enquiry by the Assessing Officer, Deepsons (India) Pvt. Ltd. vs Assistant Commissioner of Income Tax, Circle 7(1), Delhi
Brief Facts:The assessee filed return declaring total income of ₹1,02,48,020.The case was selected for scrutiny and assessment was completed by making an addition of ₹4,21,34,712 alleging under-reporting of revenue, ...
Denial of Deduction u/s 54B – Investment in Agricultural Land in Wife’s Name, Adel Saini vs. Income Tax Officer, Ward-1(1), Faridabad
Issue Involved:-Whether deduction under section 54B of the Income-tax Act, 1961 can be allowed when the sale consideration of agricultural land is invested in new agricultural land purchased in the name of the assesseeâ€...