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Completed Reassessment Cannot Be Reopened Using Ashish Agarwal: Delhi High Court Quashes Second Reassessment in Jaswant Singh Juneja v. ITO (2024)
Facts
of the CaseThe
petitioner, Jaswant Singh Juneja, is the proprietor of M/s JMK
Enterprises, engaged in the business of electronic goods and components.
For Assessment Year (AY) 2014-15, the petitioner filed his ...
Profit Attribution to Indian Permanent Establishment Independent of Global Losses: Delhi High Court Full Bench Overrules Nokia Solutions in Hyatt International Southwest Asia Ltd. v. DCIT (2024)
Facts
of the CaseHyatt
International Southwest Asia Ltd., a tax resident of the United Arab Emirates,
carried on business in India through arrangements including Strategic Oversight
Services Agreements (SOSA) with In...
Reassessment Notices Issued Post-Abhisar Buildwell Barred by Limitation: Delhi High Court Quashes Section 148 Proceedings in Good Earth Plotted Development Pvt. Ltd. v. ACIT (2024)
Facts
of the CaseGood
Earth Plotted Development Private Limited was one of the petitioners in a batch
of writ petitions challenging reassessment proceedings initiated by the Income
Tax Department after the decision o...
Reassessment Barred by Limitation Despite Ashish Agarwal: Delhi High Court Quashes Section 148 Proceedings in Genpact India Pvt. Ltd. v. ACIT (2024)
Facts
of the CaseGenpact
India Private Limited, formerly known as Empower Research Knowledge Services
Private Limited, is engaged in providing business process outsourcing,
analytics, IT services, software solutions ...
Reassessment Valid Where Facts Remain Unchanged Across Years: Delhi High Court Upholds PE, DAPE and Profit Attribution in GE Nuovo Pignone S.p.A. v. CIT (International Taxation) (2024)
Facts
of the CaseGE
Nuovo Pignone S.p.A., an Italian company (now known as Nuovo Pignone
International SRL), is part of the GE Group and engaged in the manufacture and
supply of highly specialised and customised equi...
Reassessment Proceedings Against Non-Existent Amalgamating Company Are Void Ab Initio: Delhi High Court Quashes Notices in Elite Wealth Ltd. v. ITO (2024)
Facts
of the CaseElite
Wealth Limited, the petitioner, was a part of a batch of writ petitions where
reassessment proceedings were initiated by the Income Tax Department in the
names of companies that had ceased to e...
Assessment and Reassessment in the Name of a Non-Existent Amalgamating Company Are Void: Delhi High Court Reaffirms Maruti Suzuki Principle in Ekum Design Pvt. Ltd. v. ITO (2024)
Facts
of the CaseEkum Design Private Limited was a
petitioner in a batch of writ petitions challenging assessment and reassessment
proceedings initiated by the Income Tax Department in the names of entities
that had ...
Reassessment Cannot Be Based Solely on DVO Report: Delhi High Court Quashes Section 148 Notices in Divine Infracon Pvt. Ltd. v. DCIT (2024)
Facts
of the CaseDivine
Infracon Private Limited, the petitioner, is engaged in the business of real
estate development and hospitality. A search and seizure operation under Section
132(1) of the Income-tax Act was c...
Reassessment Notices Issued Post Abhisar Buildwell Barred by Limitation: Delhi High Court Quashes Section 148 Proceedings in Dharampal Satyapal Ltd. v. DCIT (2024)
Facts
of the CaseDharampal
Satyapal Ltd. (DSL), the petitioner, is the successor entity of Abhisar
Buildwell Pvt. Ltd. (ABPL) pursuant to a court-approved scheme of arrangement.
ABPL had been subjected to a search an...
Disallowance of WIP Out of Disclosed On-Money Not Sustainable – Section 40A(3) Cannot Lead to Double Taxation; Unsecured Loan Through Banking Channel Not Taxable u/s 68 | Shanti Developers v. DCIT (ITAT Rajkot)
Shanti
Developers v. Deputy Commissioner of Income-tax ITA Nos.
827/RJT/2024 & 274/RJT/2025 (AY 2011–12)ITAT Rajkot
BenchDecision dated:
28 January 2026Coram: Dr.
Arjun Lal Saini (AM) & Dinesh Mohan S...