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Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of Permanent Establishment Profits Despite Global Losses under Article 7 DTAA & Income Tax Act
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, was engaged in providing hotel management and
oversight services in India. It entered into agreements with Indian hotel
own...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of Permanent Establishment Profits Despite Global Losses under Article 7 DTAA & Income Tax Act
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, was engaged in providing hotel management and
oversight services in India. It entered into agreements with Indian hotel
own...
Teekam Singh vs. Income Tax Officer: Appeal under Section 147 & 144 for AY 2011-12 - Non-cooperation due to Imprisonment and Restoration of Appeal for Re-adjudication
Facts of the
Case:The appeal concerns the assessment for the year
2011-12 of Sh. Teekam Singh against the Income Tax Officer (ITO), Ward-5(2)(4),
Noida, with respect to proceedings under section 147 r.w.s. 144 of the
...
Anil Kumar HUF vs ITO, Karnal – Delay in Filing Form 10-IE Due to Technical Glitch Cannot Deny Benefit u/s 115BAC (ITAT Delhi)
Facts of the
CaseThe assessee, Anil Kumar HUF, filed its
return of income for AY 2021–22 and intended to opt for the concessional tax
regime under Section 115BAC. However, the prescribed Form 10-IE was not filed wit...
Mechanical Approval under Section 153D Invalidates Search Assessment – ITAT Delhi in Kavita Jain & Others vs DCIT
Facts of the CaseA search under Section 132 was conducted in a group of connected
assessees, including the present assessees. Pursuant to the search, assessments
were framed under Section 143(3) read with Section 153A....
Mechanical Approval under Section 153D Invalidates Search Assessment – ITAT Delhi in Kavita Jain & Others vs DCIT
Facts of the CaseA search under Section 132 was conducted in a group of connected
assessees, including the present assessees. Pursuant to the search, assessments
were framed under Section 143(3) read with Section 153A....
Hindustan Power Projects Pvt. Ltd. vs Pr. CIT – No Disallowance u/s 14A Without Exempt Income | ITAT Delhi Quashes Revision u/s 263
Facts of the
CaseThe assessee, Hindustan Power Projects Pvt. Ltd.,
filed appeals before the Income Tax Appellate Tribunal (ITAT), Delhi Bench
against revisionary orders passed by the Principal Commissioner of Income T...
M/s IREO Private Limited & Ors. vs. CIT (TDS)-1 – Section 263 Invalid When Issue is Debatable & Pending in Appeal | ITAT Delhi
Facts of the
CaseThe assessee companies, engaged in real estate
development, made payments towards External
Development Charges (EDC) to HUDA on behalf of other entities. The
Assessing Officer (AO), based on informat...
M/s IREO Private Limited & Ors. vs CIT (TDS)-1 – ITAT Delhi Quashes Section 263 Revision on EDC Payments to HUDA (TDS u/s 194C vs 194I Issue, Matter Pending before CIT(A))
Facts of the
CaseThe assessee companies were engaged in real estate
business and had made payments towards External
Development Charges (EDC) to HUDA on behalf of other entities. During
TDS verification, it was found...
Remand of Addition under Section 69 due to Lack of Proper Enquiry by CIT(A): ITAT Delhi in DCIT vs. Chaudhary Ventures Pvt. Ltd. (ITA No. 1968/Del/2024)
Remand of Addition under Section 69 due to Lack of Proper Enquiry by
CIT(A): ITAT Delhi in DCIT vs. Chaudhary Ventures Pvt. Ltd. (ITA No.
1968/Del/2024)Facts of the
CaseThe assessee, Chaudhary Ventures Pvt. Ltd.,
is ...