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Reassessment Proceedings Upheld Where Independent Verification Established Escapement of Income: No Interference at Section 148A Stage – Harshit Finvest Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Harshit Finvest Pvt. Ltd., a Non-Banking Financial Company
registered with the Reserve Bank of India, challenged the order dated
30.06.2025 passed under Section 148A(3) of the Income-...
Transfer Pricing Adjustment Deleted Where ITAT Found Actual Receipt of Intra-Group Services and Faulted DRP for Non-Application of Mind; No Substantial Question of Law – PCIT Delhi-1 vs. BorgWarner Emissions Systems India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe assessee, BorgWarner Emissions Systems India Private Ltd.,
is engaged in manufacturing and marketing Exhaust Gas Recirculation (EGR)
systems and components for the automotive industry, with its reg...
Licence Fee Paid for Use of Goodwill Not Prohibited by Law; Bar Council Rules Not Attracted; Revenue Appeals Dismissed – PCIT-21 vs. Remfry & Sagar (Delhi HC)
Facts of the CaseThe Revenue filed multiple appeals under Section 260A of the
Income-tax Act, 1961 against a common assessee, M/s Remfry & Sagar, for
different assessment years. The assessee, a law firm, had paid l...
Transfer Pricing Royalty Benchmarking under CUP Sustained; Selection of Comparables a Pure Question of Fact – PCIT-7 vs. Tupperware India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed two appeals under Section 260A of the
Income-tax Act, 1961 challenging a common order dated 12.03.2025 passed by the
Income Tax Appellate Tribunal in ITA No. 9727/Del/2019 for Assessm...
No Addition under Section 153A for Unabated Years Without Incriminating Material; Revenue Appeal Dismissed Following Abhisar Buildwell – PCIT-1 vs. Mirage Homes Pvt. Ltd. (Delhi HC)
Facts of the CaseA search under Section 132 of the Income-tax Act, 1961 was
conducted in the case of the assessee group. For Assessment Year 2004–05, the
Assessing Officer completed assessment under Section 153A maki...
Penalty under Section 271(1)(c) Invalid for Defective Notice Not Specifying Charge; Revenue Appeal Dismissed on Merits and Delay – PCIT-Central-1 vs. Chetan Gupta (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A challenging the
order dated 28.06.2022 passed by the Income Tax Appellate Tribunal in ITA No.
896/Del/2015, whereby the Tribunal allowed the assessee’s ...
Section 153C Proceedings for AY 2013–14 Held Time-Barred; Six-Year Period to Be Reckoned from Date of Handing Over of Seized Material – PCIT (Central) Gurugram vs. Deepak Kumar Aggarwal (Delhi HC)
Facts of the CaseA search and seizure operation under Section 132 of the
Income-tax Act, 1961 was conducted on 02.11.2017 at the residential premises of
Prahlad Kumar Aggarwal in the case of the Rajesh Jain Group. Duri...
Low Tax Effect Objection Rejected Where Case Falls Under ‘Accommodation Entry’ Exception; Review Petition Dismissed – PCIT-1 vs. Agroha Fincap Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed ITA No. 60/2024 against Agroha Fincap Ltd.,
which was decided by the Delhi High Court on 06.10.2025. Thereafter, the
assessee filed Review Petition No. 567/2025 seeking review of the ...
Reassessment Notice for AY 2015–16 Quashed as Time-Barred under Section 149; TOLA Inapplicable – Ms. Swati Varmani vs. ITO Ward 30(1) (Delhi HC)
Facts of the CaseThe petitioner, Ms. Swati Varmani, filed a writ petition
challenging notice dated 25.05.2022 issued under Section 148A(b), order dated
26.07.2022 passed under Section 148A(d), and notice dated 26.07.20...
Condonation of Delay under Section 119(2)(b) Denied Where No Genuine Hardship Shown; Ignorance of Law Not a Ground – Manjit Singh Dhaliwal vs. CIT (International Taxation) (Delhi HC)
Facts of the CaseThe petitioner, Manjit Singh Dhaliwal, a Canadian citizen and
non-resident for Assessment Year 2020–21, sought condonation of delay in filing
his income tax return for the said year under Section 119...