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Director of Income Tax (Exemption) vs. Vishwa Jagriti Mission: Interpretation of Genuineness of Activities under Section 12AA and Corporate/Individual Fiduciary Liability
Facts of the Case
Assessee
Profile: The Respondent, Vishwa Jagriti Mission, was
incorporated as a society on May 10, 1993, under the Societies
Registration Act, 1860, with an object clause defining it...
Director of Income Tax (Exemption) vs. Vishwa Jagriti Mission: Delhi High Court Judgment on Condonation of Delay and Registration of Charitable Trusts under Section 12A/12AA of the Income Tax Act, 1961
Facts of the Case·
Assessee Profile: The respondent-assessee, Vishwa
Jagriti Mission, is a society registered under the Societies Registration Act,
1860, running with o...
Xerox Modicorp Ltd. Vs. Deputy Commissioner of Income Tax: Validity of Reopening Assessment Under Section 147/148 Based on Change of Opinion
Facts of the CaseThe petitioner, Xerox Modicorp Ltd., filed multiple writ
petitions challenging notices issued by the Assessing Officer (AO) under Section
148 of the Income Tax Act, 1961, aiming to reopen their conclud...
Delhi High Court in M/s Xerox Modicorp Ltd. vs. DCIT: Reassessment Notices u/s 147/148 Quashed; Recorded Reasons Cannot Be Supplemented for Post-4-Year Reopenings, and Audit Opinions Do Not Constitute Tangible Material Within 4 Years
Facts of the Case
The
Petitioner’s Profile: The petitioner is a company engaged in
the export of software, the manufacture of photocopiers, and trading in
fax machines, paper, and toner.
The
...
Rollatainers Limited vs Deputy Commissioner of Income Tax – Reassessment under Section 148/147 of Income Tax Act, 1961
Facts of the
Case
Petitioner, Rollatainers Limited, is engaged in the
manufacturing of packing materials.
Filed its return for AY 2003-04 declaring a loss of ₹2.48 crores.
Original assessment complet...
Commissioner of Income Tax vs. Samsung India Electronics Ltd. | Deductibility of Interregnum Expenses Under Section 37 of Income Tax Act
Facts of the CaseThe respondent-assessee, Samsung India Electronics
Ltd., is a joint venture company incorporated on August 3, 1995. The company
received its certificate of commencement of business on August 29, 1995.
...
DIRECTOR OF INCOME TAX vs. McDONALDS CORPORATION: Validity of Reassessment Proceedings Under Section 147/148 Based on a Mere Change of Opinion Where Primary Facts Were Fully Disclosed
Facts of the Case
The
Arrangement: The assessee, McDonalds Corporation (USA),
entered into a Master Licensing Agreement (MLA) on January 1, 1996, with
McDonalds India Private Limited (MIPL). Under thi...
Commissioner of Income Tax vs Samsung India Electronics Ltd. – Defective Stock Valuation under Section 115JA and Allowability of Employee Training Expenses | Delhi High Court
Facts
of the Case
The assessee, Samsung India
Electronics Ltd., had written off defective stock amounting to
Rs.1,20,07,908/- by valuing it at realizable market value, which was lower
than the cost p...
The Commissioner of Income Tax Vs. M/s Intercontinental Trading & Investment Co. Ltd. (On the Mandatory Requirement of Recording Satisfaction for Assuming Jurisdiction Under Section 158BD of the Income Tax Act, 1961)
Facts of the Case
Search
and Seizure: A search operation under Section 132 of the
Income Tax Act, 1961, was conducted on November 22, 1996, at the premises
of M/s Hindustan Development Corporation Lim...
JD Tytler School Society vs. Director General of Income Tax (Exemption) & Anr. — Remand of Exemption Claims Under Section 10(23C)(vi) Following Post-Order Amendment of Memorandum of Association
Facts of the Case
Parties
Involved: The petitioner is the JD Tytler School
Society , and the respondents are the Director General of Income Tax
(Exemption) and others.
Impugned
Orders: The pe...