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THE PR. COMMISSIONER OF INCOME TAX-6 vs. MOET HENNESSY INDIA PVT. LTD. (Delhi High Court | Transfer Pricing – AMP Expenses | Sections 92B, 92CA, 143(3), 144C of Income Tax Act, 1961)
Facts of the
CaseThe Assessee, Moet Hennessy India Pvt. Ltd., filed
its return of income declaring losses for AY 2009-10 and AY 2010-11. The case
was selected for scrutiny, and it was observed that the Assessee had en...
I A Housing Solution Pvt. Ltd. & Anr. vs Principal Commissioner of Income Tax (Delhi High Court, 2022) – Delay in Payment under Vivad Se Vishwas Act Condoned Due to Extraordinary Circumstances
Facts of the
CaseThe petitioners filed declarations (Form 1 and Form
2) under the Vivad Se Vishwas Act, 2020 on 04 March 2021 to settle
pending tax disputes. The department issued Form 3 determining the payable
amoun...
Principal Commissioner of Income Tax, Central-3, Delhi vs Alchemist Capital Ltd (Delhi High Court) – Section 153A Assessment Without Incriminating Material | AY 2010-11
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court challenging the order dated 18.08.2022 passed by the
Income Tax Appellate Tribunal for Assessment Year 2010–2011. The assessme...
PR. Commissioner of Income Tax–4 vs Moet Hennessy (India) Pvt. Ltd. (Delhi High Court) – AMP Expenditure, BLT Method & Section 37(1) Disallowance
Facts of the
CaseThe assessee, Moet Hennessy (India) Pvt. Ltd.,
filed its return of income for AY 2011–12, which was subjected to scrutiny. The
Assessing Officer (AO) referred international transactions with Associa...
I A Housing Solution Pvt. Ltd. & Anr. vs Principal Commissioner of Income Tax & Ors. (Delhi High Court, 2022) – Delay in Payment under Vivad Se Vishwas Scheme Condoned due to Extraordinary Circumstances
Facts of the
CaseThe petitioners filed declarations (Form 1 & 2)
under the Vivad Se Vishwas Scheme on 04 March 2021 to settle pending tax
disputes. The designated authority issued Form 3 determining the payable
a...
VMVS Textiles Private Limited vs Income Tax Officer Ward 26(1) & Anr. | Delhi High Court | Section 148A(d) Reassessment Quashed Due to Erroneous Computation of Alleged Escaped Income
Facts of the
Case
The case pertains to Assessment Year 2013–2014.
The petitioner was accused of being a beneficiary of accommodation
entries from:
Gopalpriya Commercial Pvt. Ltd.
Lookline Vincom ...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – No Substantial Question of Law on PE Attribution, Royalty vs Business Income & Section 234B Liability
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against a common order dated 26.10.2020 passed by
the Income Tax Appellate Tribunal concerning Assessment Years 2007–08, 200...
Rajasthan Global Securities Pvt. Ltd. vs Assistant Commissioner of Income Tax Circle 19(1), Delhi (2022) – Reassessment Notice on Non-Existent Entity Invalid under Income Tax Act
Facts of the
CaseThe petitioner, Rajasthan Global Securities Pvt.
Ltd., successor to Aureole Impex Pvt. Ltd., challenged reassessment proceedings
initiated by the Income Tax Department for Assessment Year 2013–14.
...
Commissioner of Income Tax (Exemptions), Delhi vs Mata Parvati Educational & Innovative Society – Section 12AA Registration Cannot Be Denied on Grounds of Application of Income | Delhi High Court
Facts of the CaseThe Revenue filed an appeal challenging the order
of the Income Tax Appellate Tribunal (ITAT), which directed grant of
registration under Section 12AA to the respondent society. The respondent
s...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – No Substantial Question of Law on PE Attribution, Royalty vs Business Income & Section 234B Liability
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against a common order dated 26.10.2020 passed by
the Income Tax Appellate Tribunal concerning Assessment Years 2007–08, 200...