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Reassessment Initiated During Pending Scrutiny Assessment Is Without Jurisdiction; Parallel Proceedings under Sections 147 and 143(3) Impermissible – Salesforce.com Singapore Pte. Ltd. vs. DCIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Salesforce.com Singapore Pte. Ltd., filed a writ petition challenging the
assessment order dated 21.01.2025 passed under Section 147 read with Section
144C(13) of the Income-tax Act, ...
Reassessment Notice for AY 2015–16 Issued After 1 April 2021 Is Time-Barred; Proceedings Quashed Following Rajeev Bansal – Roopa Goyal vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Roopa Goyal, filed a writ petition challenging the initial notice dated
23.06.2021 issued under Section 148 of the Income-tax Act, 1961, subsequent
notices dated 31.05.2022, the order...
Reassessment Notices for AY 2015–16 Issued After 1 April 2021 Liable to Be Dropped in View of Revenue Concession in Rajeev Bansal; Section 148 Proceedings Quashed – Rangoli Infocom Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Rangoli Infocom Private Limited, filed a writ petition challenging the notice
dated 27.04.2021 issued under Section 148 of the Income-tax Act, 1961, the
notice dated 27.05.2022 issued...
Reassessment for AY 2013–14 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO to Examine Limitation Afresh – Rajesh Agarwal vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Rajesh Agarwal, filed a writ petition challenging the initial notice dated
17.06.2021 issued under Section 148 of the Income-tax Act, 1961, subsequent
notices dated 24.05.2022, the or...
Sanction for Prosecution under Section 279 Validly Granted by Principal Director; Criminal Proceedings under Sections 276C(1) and 277A Not Premature – Raj Kumar Kedia vs. Income Tax Office (Delhi High Court)
Facts of the
CaseThe petitioner,
Raj Kumar Kedia, filed two petitions under Section 482 of the Code of Criminal
Procedure read with Article 227 of the Constitution seeking quashing of
Criminal Complaint Nos. 516654/2...
Addition under Section 68 Not Sustainable Where Identity, Creditworthiness and Genuineness of Share Applicants Established; No Requirement to Prove Source of Source for AY 2012–13 – Revenue Appeal Dismissed – PCIT-1 vs. Central Plastics Pvt. Ltd. (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the order
dated 31.05.2023 passed by the Income Tax Appellate Tribunal in ITA No.
65/Del/2017 for Assessment Yea...
Section 50C Not Applicable Where Agreement to Sell and Stamp Duty Precede Circle Rate Enhancement; No Substantial Question of Law – PCIT Delhi-7 vs. Thomson Press (India) Ltd. (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the order
dated 30.06.2023 passed by the Income Tax Appellate Tribunal in ITA No.
9342/Del/2019 for Assessment Y...
No Disallowance under Section 14A Where No Exempt Income Earned; Section 263 Cannot Be Invoked on a Plausible View – Revenue Appeal Dismissed – PCIT (Central)-2 vs. Hindustan Power Projects Pvt. Ltd. (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the common
order dated 31.12.2024 passed by the Income Tax Appellate Tribunal in ITA Nos.
2747/Del/2024 and 2748...
Section 153C Proceedings Invalid Without Year-Specific Incriminating Material; Notices for AYs 2015–16 to 2020–21 Quashed – Neeraj Bharadwaj vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Neeraj Bharadwaj, challenged multiple notices dated 24.06.2024 issued under
Section 153C of the Income-tax Act, 1961 for Assessment Years 2015–16 to
2020–21. The notices were issu...
Search-Based Reassessment for AY 2014–15 Barred by Limitation; Ten-Year Block under Section 153A Computed from AY of Search – Notice under Section 148 Quashed – N S Associates Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner, N
S Associates Private Limited, filed a writ petition challenging the notice
dated 04.02.2025 issued under Section 148 of the Income-tax Act, 1961 for
Assessment Year 2014–15 and th...