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Reassessment Notices Quashed Where Reasons Do Not Survive: Delhi High Court in Experion Developers Pvt. Ltd. v. Assistant Commissioner of Income Tax Reaffirms Limits of Section 148 Reopening
Facts of the
CaseThe batch of writ petitions was filed by Experion
Developers Pvt. Ltd. and Experion Hospitality Pvt. Ltd. challenging notices
issued under Section 148 of the Income Tax Act, 1961 for Assessment Years
...
Reassessment Proceedings Quashed for Non-Issuance of Notice under Section 143(2): Delhi High Court Upholds ITAT Order in CIT (International Taxation) v. Oracle Systems Corporation
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order dated 26.09.2022 passed by the Income Tax
Appellate Tribunal (ITAT) relating to Assessment Years 1997-98, 1998...
Mechanical Approval Under Section 151 Invalidates Reassessment Notice; Mere “Yes, I Am Satisfied” Not Enough – Capital Broadways Pvt. Ltd. vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Capital Broadways Pvt. Ltd., filed its
return of income for Assessment Year 2010-11 on 05.08.2010,
declaring an income of ₹1,95,711. The return was processed under Section
143(1) of ...
Mechanical Approval Under Section 151 Invalidates Reassessment Notice; Mere “Yes, I Am Satisfied” Not Enough – Capital Broadways Pvt. Ltd. vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Capital Broadways Pvt. Ltd., filed its
return of income for Assessment Year 2010-11 on 05.08.2010,
declaring an income of ₹1,95,711. The return was processed under Section
143(1) of ...
High Brand Value and Economic Scale Render BPO Giants Incomparable; TCS E-Serve and Infosys BPO Excluded from ALP Analysis – Cadence Design Systems (India) Pvt. Ltd. vs DCIT (Delhi High Court)
Facts of the CaseThe appellant, Cadence Design Systems (India) Private Limited,
challenged the order dated 05.01.2018 passed by the Income Tax Appellate
Tribunal for Assessment Year 2010-11, which had upheld the inclus...
Assessment Order Not Invalid Merely Due to Incorrect Heading or DIN Reference; Substance Prevails Over Form – BT Global Communications India Pvt. Ltd. vs DCIT (Delhi High Court)
Facts of the CaseThe petitioner, BT Global Communications India Pvt. Ltd.,
challenged an order dated 06.12.2019 passed by the Assessing Officer
assessing its total income at ₹5,47,92,27,510 for Assessment Year
2016-...
Reassessment Notices Issued by Jurisdictional Assessing Officer Invalid under Faceless Reassessment Scheme – Bishamber Dayal Chander Mohan v. ITO (Ward 58(3)), Delhi High Court
Facts of the CaseThe petitioner challenged multiple reassessment notices issued
under Section 148 of the Income Tax Act, 1961, along with orders passed
under Section 148A(d), all issued by the Jurisdictional Assessing
...
Notice Under Section 143(2) Can Be Issued by Prescribed Income-Tax Authority Authorised by CBDT; Jurisdictional Challenge Rejected – Ambience Towers Pvt. Ltd. vs ACIT (Delhi High Court)
Facts of the CaseThe petitioner, Ambience Towers Private Limited, filed
a writ petition challenging a notice dated 23.06.2024 issued under Section
143(2) of the Income Tax Act, 1961, along with subsequent notices dated...
Notice Under Section 143(2) Validly Issued by Prescribed Income-tax Authority; CBDT Authorisation Under Rule 12E Upheld – Ambience Farms Pvt. Ltd. vs ACIT (Delhi High Court)
Facts of the CaseThe petitioner, Ambience Farms Private Limited, filed a
writ petition challenging a notice dated 23.06.2024 issued under Section
143(2) of the Income Tax Act, 1961, along with subsequent notices dated ...
Transfer Pricing Comparables Must Reflect Functional Similarity and Business Model; Tribunal Order Set Aside and Matter Remanded – Alcatel Lucent India Limited vs DCIT (Delhi High Court)
Facts of the CaseThe appellant, Alcatel Lucent India Limited, filed
appeals under Section 260A of the Income Tax Act, 1961, challenging a
common order dated 16.08.2021 passed by the Income Tax Appellate
Tribunal for A...