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Principal Commissioner of Income Tax-3 vs Fujitsu India Pvt. Ltd. – RPM vs TNMM in Transfer Pricing for Pure Distributor (Delhi High Court)

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 216
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Facts of the CaseThe assessee, Fujitsu India Pvt. Ltd., was engaged in distribution activities, purchasing goods from its associated enterprises (AEs) and reselling them in India without any value addition.The Transfe...

PR. Commissioner of Income Tax-3 vs Fujitsu India Private Limited (Delhi High Court) – Applicability of Resale Price Method (RPM) vs TNMM for ALP Determination under Sections 144C & 143(3)

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 393
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Facts of the CaseThe case pertains to Assessment Years 2011-12, 2012-13, and 2013-14, where the Assessing Officer passed orders under Section 144C read with Section 143(3). The Transfer Pricing Officer (TPO) determine...

PR. Commissioner of Income Tax–3 vs Fujitsu India Pvt. Ltd. | Delhi High Court | Section 144C r/w 143(3) | Transfer Pricing – RPM vs TNMM for ALP Determination

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 390
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Facts of the CaseThe present matter pertains to appeals filed by the Revenue against Fujitsu India Private Limited for Assessment Years 2011–12, 2012–13, and 2013–14.The Assessing Officer (AO) passed assessment ...

The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 177
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Facts of the CaseThe Revenue filed an appeal against the order of the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...

The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)

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My Tax Expert
07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 162
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Facts of the CaseThe Revenue filed an appeal against the order of the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...

Commissioner of Income Tax (International Taxation)-1, New Delhi vs Cobra Instalaciones y Servicios S.A | Delhi High Court | Engineering Fees Disallowance | Transfer Pricing & ALP

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 191
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Facts of the Case The respondent/assessee incurred engineering expenses for execution of a project related to Delhi Metro Rail Corporation (DMRC). The assessee paid engineering fees to its head office. The...

Mehra Jewel Palace Pvt. Ltd. vs Pr. Commissioner of Income Tax – Section 40A(2)(b) Disallowance & Opportunity of Hearing (Delhi High Court)

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 206
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Facts of the CaseThe assessee, Mehra Jewel Palace Pvt. Ltd., filed appeals before the Delhi High Court challenging orders of the Income Tax Appellate Tribunal for AY 2011–12 and AY 2012–13. Two primary issues aros...

PR. Commissioner of Income Tax, Delhi-7 vs Techno Trexim (India) Pvt. Ltd. | Section 14A r/w Rule 8D – No Disallowance in Absence of Exempt Income (Delhi High Court)

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 188
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Facts of the CaseThe present appeal was filed by the Revenue against the order dated 05.09.2022 passed by the Income Tax Appellate Tribunal concerning Assessment Year 2015–16.The Tribunal had deleted the disallowanc...

PR. Commissioner of Income Tax-7, Delhi vs Times Internet Limited | Delhi High Court | Section 14A, 37(1), Depreciation on Software & Revenue vs Capital Expenditure | AY 2012-13

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 204
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Facts of the CaseThe Revenue filed an appeal challenging the order of the Income Tax Appellate Tribunal dated 30.03.2021 concerning multiple disallowances made by the Assessing Officer (AO) against the assessee, Times...

M/s Tirupati Trading Corporation vs Assistant Commissioner of Income Tax (Delhi High Court, 2023) – Reassessment Proceedings Quashed Due to Lack of Material under Sections 148 & 148A(d) of Income Tax Act

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07/04/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 220
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Facts of the Case The petitioner, M/s Tirupati Trading Corporation, challenged: Order dated 28.07.2022 passed under Section 148A(d) Consequential notice under Section 148 for AY 2016–17 The Re...