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Principal Commissioner of Income Tax-4 vs Headstrong Services India Pvt. Ltd. (2020) – Section 144C Non-Compliance Renders Assessment Void Ab Initio
Facts of the
CaseThe respondent-assessee, Headstrong Services India
Pvt. Ltd., filed its return declaring income for AY 2007–08. The case was
selected for scrutiny, and reference was made to the Transfer Prici...
PR. Commissioner of Income Tax-3, New Delhi vs DKG Finance & Chit Fund Pvt. Ltd. | Delhi High Court | Low Tax Effect Appeal Dismissed under CBDT Circular 17/2019
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the respondent/assessee, DKG Finance & Chit
Fund Pvt. Ltd. During the proceedings, the respondent filed an applicati...
Microsoft India (R&D) Pvt. Ltd. vs Deputy Commissioner of Income Tax & Ors. | Delhi High Court | Transfer Pricing – Comparable Selection & Section 92B(2), 10A, 143(3), 144C Analysis
Facts of the
Case
The assessee, Microsoft India (R&D) Pvt. Ltd., is
engaged in software development and IT-enabled services and is a
subsidiary of Microsoft Ireland Research Ltd.
For AY 2011-12, the...
Microsoft India (R&D) Pvt. Ltd. vs Deputy Commissioner of Income Tax & Ors. | Delhi High Court | Section 260A | Transfer Pricing – Exclusion of Comparables & Remand by ITAT
Facts of the
Case
The Assessee, Microsoft India (R&D) Pvt. Ltd., is engaged in
software development and IT-enabled services.
For AY 2011-12, it declared income of over ₹201 crore.
The case was referr...
Microsoft India (R&D) Pvt. Ltd. vs Deputy Commissioner of Income Tax & Anr. (Delhi High Court) – Transfer Pricing | Section 92B, Rule 10B, Section 260A | Exclusion of Comparables & Remand Jurisdiction
Facts of the
CaseThe Assessee, Microsoft India (R&D) Pvt. Ltd.,
a subsidiary of Microsoft Corporation USA, is engaged in software development
and IT-enabled services. It filed its return declaring income of
₹2,...
Microsoft India (R&D) Pvt. Ltd. vs Deputy Commissioner of Income Tax & Ors. (Delhi High Court, 2021) – Transfer Pricing Comparables & ALP Determination under Section 92B, Rule 10B
Facts of the Case
The
Assessee, Microsoft India (R&D) Pvt. Ltd., is engaged in software
development and IT-enabled services.
It
filed its return declaring income of ₹2,01,64,26,819 for AY 201...
Anil Singhal vs Directorate of Income Tax Investigation & Anr. (2021:DHC:20-DB) – Abuse of Process of Court in Tax Evasion Petitions under Income Tax Informants Reward Scheme
Facts of the CaseThe petitioner, Anil Singhal, filed a writ petition
seeking a mandamus directing the Directorate of Income Tax Investigation
and CBDT authorities to conduct a time-bound investigation based on Tax
Eva...
Principal Commissioner of Income Tax–12 vs Smt. Krishna Devi & Ors. (Delhi High Court) – Bogus LTCG Addition u/s 68 & 115BBE Not Sustainable Without Evidence
Facts of the Case
The
assessee declared income including exempt LTCG under Section 10(38).
The
Assessing Officer (AO) treated LTCG from sale of shares of M/s Gold Line
International Finvest Ltd. as...
Principal Commissioner of Income Tax-12 vs Smt. Krishna Devi & Ors. (Delhi High Court) – Addition under Section 68 r/w 115BBE on Alleged Bogus LTCG from Penny Stocks Deleted
Facts of the CaseThe present appeals were filed by the Revenue under Section
260A of the Income Tax Act, 1961 against a common order passed by the Income
Tax Appellate Tribunal (ITAT). The Respondent-Assessee, an indiv...
Principal Commissioner of Income Tax-12 vs Smt. Krishna Devi & Ors. (Delhi High Court) – Addition under Section 68 on Alleged Bogus LTCG from Penny Stocks Unsustainable Without Independent Enquiry
Facts of the CaseThe Respondent-Assessees, including Smt. Krishna Devi, had
declared income from various sources and claimed exemption of Long-Term Capital
Gains (LTCG) under Section 10(38) arising from sale of shares ...