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Commissioner of Income-Tax-V vs. Ramsons Organics Limited: Section 10B Deduction Allowed for Marble, Granite and Stone Processing as Manufacturing Activity
Facts of the Case
Assessee's
Business: The Assessee is engaged in running a
100% Export Oriented Unit (EOU) at Dhoka, Gurgaon, dealing in the business
of processing stone, marble, granite, etc., and e...
Reinterpreting Capital vs. Revenue Expenditure: A Comprehensive Analysis of the Delhi High Court’s Landmark Judgment in CIT vs. Selan Exploration Technology Ltd.
Facts of the CaseThe respondent (hereinafter referred to as the
"assessee") is a limited company engaged in business activities
concerning crude oil production across three oil fields (Bakrol, Indora, and
Lohar) with ...
Commissioner of Income Tax vs. Assessee (ITA No. 225/2007) | Delhi High Court – Interest Income from Fixed Deposits Not Eligible for Section 80HHC Deduction; Bank Charges Cannot Be Reduced from Export Turnover
Facts of the
Case
The assessee claimed deduction under Section 80HHC in respect of
interest income amounting to Rs. 53,32,448 earned from fixed deposits with
banks and companies.
The assessee also incurr...
Commissioner of Income Tax-III vs. Senior India Private Limited: Revenue vs. Capital Expenditure on Trademark Licence Fees and Technical Know-How Royalty under Sections 32(1)(ii) and 260A of the Income-Tax Act
Facts of the CaseThe Respondent-Assessee ($M/s$ Senior India
Private Limited) is an Indian company engaged in the manufacturing of flexible
metal hoses and assemblies. Incorporated on October 1, 1996, the company
shor...
Commissioner of Income Tax, Delhi-II vs. KSA Technopak (India) Pvt. Ltd. Section 80-O Deduction – Only Common Expenses Can Be Apportioned Between Domestic and Foreign Earnings; Exclusively Domestic Expenses Cannot Be Allocated to Foreign Receipts
Facts of the
Case
The assessee earned consultancy income from both domestic and
foreign clients.
Foreign consultancy receipts amounted to ₹1,11,63,213.
Deduction under Section 80-O amounting to ₹48,28,47...
Commissioner of Income Tax, New Delhi vs. Singapore Airlines Ltd. (and connected appeals: KLM Royal Dutch Airlines, Pakistan International Airlines Corp., Kuwait Airways Corporation, Air France, Thai Airways International Public Co. Ltd., British Airways PLC, M/S Air India Ltd., Lufthansa German Airlines, Belair Travels & Cargo P. Ltd., United Airlines)
Facts of the Case
The
Revenue preferred a batch of appeals against various international and
domestic airline assessees operating in India.
The
core operational model involved the airlines supplyin...
Commissioner of Income Tax vs. Pawan Gupta: Delhi High Court Judgment on Mandate of Section 143(2) Notice Within Chapter XIV-B Block Assessment Under Section 158BC of the Income Tax Act, 1961 — Determination of Jurisdictional Pre-requisite versus Procedural Irregularity in Search and Seizure Cases
Facts of the Case
Context
of Proceedings: The matter arose from a batch of appeals
led by CIT v. Pawan Gupta (ITA No. 200/2008), involving multiple
assessees belonging to the same business group.
S...
The Doctrine of Foundational Collapse: A Detailed Analysis of Commissioner of Income Tax vs. Respondent (2009:DHC:13343-DB) Regarding the Nullity of Consequential Orders Post-Section 263 Revision
Facts of the CaseThe present appeal was preferred by the Revenue (Appellant)
against the order of the Income Tax Appellate Tribunal (ITAT). The initiating
action in this matter traced back to an assessment order passed...
Shivani Textiles Ltd. vs. Deputy Commissioner of Income Tax | Bad Debt vs. Trading Loss under Sections 36(1)(vii), 36(2) & 37(1) of the Income Tax Act
Facts of the
CaseThe assessee, Shivani Textiles Ltd., filed its
return for Assessment Year 1997-98 and claimed a deduction of ₹53,57,964.76 as
a bad debt written off. The amount represented advances made to M/s Body...
Shipra Srivastava & AnR. Vs. Assistant Commissioner of Income Tax: Validity of Reopening Assessment u/s 147/148 Based on Erroneous Assumptions without New Material
Facts of the Case
The
petitioners (husband and wife) are Doctors employed with Escorts Heart
Institute and Research Centre Ltd. (EHIRCL).
They
filed their return of income for Assessment Year (AY) 2...