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Commissioner of Income Tax v. Ankitech Pvt. Ltd. & Connected Matters | Delhi High Court on Taxability of Deemed Dividend under Section 2(22)(e) of the Income Tax Act
Facts of the Case
The assessees in the batch of appeals were companies or concerns
which had received loans, advances, or financial accommodations from
closely-held companies.
The lending companies po...
Commissioner of Income Tax v. Ankitech Pvt. Ltd. & Connected Matters | Delhi High Court on Taxability of Deemed Dividend under Section 2(22)(e) of the Income Tax Act
Facts of the Case
The assessees in the batch of appeals were companies or concerns
which had received loans, advances, or financial accommodations from
closely-held companies.
The lending companies posses...
AREVA T&D SA vs The Asst. Director of Income Tax & Ors. | Delhi HC Case on Income Escaping Assessment & Certificate Under Section 197
Facts of the Case
The
petitioner, AREVA T&D SA, was awarded multiple contracts by Power Grid
Corporation of India Ltd. (PGCIL) for onshore and offshore supply and
services (Page 3–5).
PGCIL
...
Commissioner of Income Tax v. Nestle India Ltd. | Allowability of Royalty Payment to Associated Enterprises under Section 40A(2), Section 92 and Article 9 of India-Switzerland DTAA | Delhi High Court
Facts of the Case
Nestle India Ltd. was engaged in the manufacture and marketing of
food products and beverages in India.
The company paid substantial royalty and technical know-how fees to
its foreign gr...
Commissioner of Income Tax v. Nestle India Ltd. | Allowability of Royalty Payment to Associated Enterprises under Section 40A(2), Section 92 and Article 9 of India-Switzerland DTAA | Delhi High Court
Facts of the Case
Nestle India Ltd. was engaged in the manufacture and marketing of
food products and beverages in India.
The company paid substantial royalty and technical know-how fees to
its foreign gr...
Commissioner of Income Tax vs. Goyal M.G. Gases Pvt. Ltd. (2011) – Interest on Sticky Loans Not Taxable Under Real Income Theory Despite Mercantile Accounting | Delhi High Court
Facts of the CaseThe assessee company was engaged in financing
activities through loans, Inter-Corporate Deposits (ICDs), bill discounting,
and similar transactions.For accounting purposes under the Companies Act,
the...
Fab India Overseas Pvt. Ltd. vs Commissioner of Income Tax (Delhi High Court) – Scope of Revision under Section 263, Transfer Pricing Reference to TPO, and Distinction Between Lack of Inquiry and Inadequate Inquiry
Facts of the Case
The assessee, Fab India Overseas Pvt. Ltd., was engaged in export
and local trading of handloom products and readymade garments.
For Assessment Year 2004-05, it filed its return declaring inco...
Commissioner of Income Tax v. [Assessee] – Whether UPS is Eligible for 60% Depreciation as Part of Computer System or Only 25% as Power Supply Equipment | Delhi High Court
Facts of the Case
The assessee purchased and used UPS devices along with its computer
systems.
Depreciation at the rate of 60% was claimed on UPS by treating it
as part of the computer system.
The Asses...
Director of Income Tax vs Brahmaputra Capital Financial Services Ltd. | Interest on NPA Not Taxable on Accrual Basis for NBFCs | Delhi High Court
Facts of the Case
The assessee, Brahmaputra Capital Financial Services Ltd.,
was a Non-Banking Financial Company (NBFC).
It had advanced interest-bearing loans aggregating approximately
₹13.57 crore to ...
Director of Income Tax vs. Brahmaputra Capital Financial Services Ltd. (2011) 2011:DHC:2801-DB | Interest on NPA Not Taxable on Accrual Basis for NBFCs Under Real Income Theory
Facts of the CaseThe assessee, Brahmaputra Capital Financial
Services Ltd., a registered Non-Banking Financial Company (NBFC), had advanced
interest-bearing loans aggregating to approximately ₹13.57 crores to certain...