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Pr. Commissioner of Income Tax (Central)-3 vs Suncity Projects Pvt. Ltd. | Delhi High Court | Condonation of Delay Rejected for Failure to Explain 86 Days’ Delay under Section 260A of the Income Tax Act
Facts of the
Case
The Revenue preferred multiple appeals against the order of the
Income Tax Appellate Tribunal.
There was a delay of 86 days in filing the appeals before
the High Court.
Applications...
Pr. Commissioner of Income Tax–4 vs. Gunvardhan Vyapar Pvt. Ltd. | Delhi High Court | Scope of Addition under Section 153A in Absence of Incriminating Material | Sections 132 & 153A of the Income-tax Act, 1961
Facts of the CaseThe Revenue preferred appeals before the Delhi High
Court challenging the order passed in favour of Gunvardhan Vyapar Pvt. Ltd. The
dispute arose in the context of assessment proceedings under Section ...
Rollatainers Ltd. vs Commissioner of Income Tax (Delhi High Court) – Section 80HHC Deduction on Export Profits, Indirect Costs & Written Back Liabilities under Explanation (baa) | AY 1994-95
Facts of the
CaseThe assessee, Rollatainers Ltd., was engaged in
multiple business divisions including packaging, paper board, machinery
manufacture, specialty paper, and machine trading. During the relevant
assessme...
Pr. Commissioner of Income Tax-4 vs Gunvardhan Vyapar Pvt. Ltd. | Delhi High Court on Scope of Section 153A Assessments in Absence of Incriminating Material
Facts of the
CaseThe Revenue preferred appeals against the assessee
challenging the order passed by the Income Tax Appellate Tribunal. The dispute
arose from assessment proceedings initiated pursuant to search proceed...
Shanghai Electric Group Co. Ltd. vs Deputy Commissioner of Income Tax & Anr. | Delhi High Court on Stay of Tax Demand in Permanent Establishment (PE) Taxation Dispute under Income Tax Act
Facts of the
Case
The petitioner is a multinational company engaged in multiple
projects in India.
The Revenue authorities held that the petitioner had a Permanent
Establishment (PE) in India and was li...
Shanghai Electric Group Co. Ltd. vs Deputy Commissioner of Income Tax & Anr. | Delhi High Court on Stay of Tax Demand, Permanent Establishment (PE) Dispute and ITAT Expedited Hearing
Facts of the
CaseThe petitioner, Shanghai Electric Group Co. Ltd.,
had pending appeals before the ITAT for Assessment Years 2007–08 to 2011–12,
where recovery proceedings had remained stayed. For Assessment Years ...
Tax Sparing Credit under India–Oman DTAA on Dividend Income from OMIFCO | Scope of Revision under Section 263 of the Income-tax Act, 1961
Facts of the
CaseThe assessee, Krishak Bharati Cooperative Ltd.
(KRIBHCO), a multi-state cooperative society engaged in the manufacture of
fertilizers, entered into a joint venture with Oman Oil Company and formed Oma...
Pr. Commissioner of Income Tax vs Krishak Bharati Cooperative Ltd. (KRIBHCO) | Delhi High Court on Tax Sparing Credit under India–Oman DTAA, Section 90 & Revision under Section 263 of the Income Tax Act
Facts of the
CaseKrishak Bharati Cooperative Ltd. (KRIBHCO), a
multi-state cooperative society engaged in fertilizer manufacturing, entered
into a joint venture with Oman Oil Company for incorporation of Oman India
F...
Commissioner of Income Tax-IV vs. M/s Ester Industries Ltd. Delhi High Court Dismisses Revenue’s Income Tax Appeals on Ground of 860 Days’ Delay in Re-filing – Absence of “Sufficient Cause” for Condonation of Delay under the Income-tax Act
Facts of the
CaseThe matter arose before the Delhi High Court in two
connected Income Tax Appeals filed by the Revenue, namely ITA No. 137/2017 and
ITA No. 139/2017. The appellant, Commissioner of Income Tax-IV, sough...
Commissioner of Income Tax-IV vs M/s Ester Industries Ltd. | Delay in Re-filing Income Tax Appeal Cannot Be Condoned Without Sufficient Cause | Delhi High Court | Sections 260A & Limitation Principles
Facts of the
CaseThe Revenue preferred two income tax appeals before
the Delhi High Court against M/s Ester Industries Ltd. However, the appeals
suffered from an inordinate delay of 860 days in re-filing.To justify th...