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PR. Commissioner of Income Tax-7 vs Trinity Insurance Brokers Pvt. Ltd. (Delhi High Court, ITA 624/2023, AY 2011-12) – Allowability of Supervisory & Risk Management Expenses u/s 37(1)
Facts of the
CaseThe present appeal was filed by the Revenue against
the order dated 19.08.2021 passed by the Income Tax Appellate Tribunal
concerning Assessment Year 2011–12.The respondent-assessee, engaged in the ...
Pr. Commissioner of Income Tax-7 vs Verizone Communications India Pvt. Ltd. | Section 80IA & 40(a)(i)/(ia) | Delhi High Court Judgment (2023)
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court challenging the order of the Income Tax Appellate Tribunal
(ITAT) dated 20.03.2020 for Assessment Year 2011–12.The respondent ...
Saraswati Petrochem Pvt. Ltd. vs Income Tax Officer, Ward 22(3) – Reassessment Invalid Without Tangible Material under Sections 147 & 148 of Income Tax Act
Facts of the
CaseThe petitioner, Saraswati Petrochem Pvt. Ltd.,
filed its Return of Income for AY 2011–12, which was processed under Section
143(1) of the Income Tax Act, 1961.After a lapse of more than six years, t...
PR. Commissioner of Income Tax–1, Delhi vs M/s Dart Infrabuild (P) Ltd. (Delhi High Court) – Invalid Reassessment Due to Improper Service of Notice u/s 148 & Non-Issuance of Mandatory Notice u/s 143(2) | Sections 147, 148, 143(2), 144, 292BB, 68, 14A of Income-tax Act
Facts of the
CaseThe present appeal arose from Assessment Year
2010–11 wherein the Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT).The assessee, M/s Dart Infrabuild Pvt. Ltd., had
changed i...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP (Delhi High Court, AY 2013–14) – Appeal Dismissed Following Sheraton International Precedent
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the order dated 07.01.2020 passed by the Income
Tax Appellate Tribunal (ITAT) concerning Assessment Year 2013–14.The a...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP (Delhi High Court) – ITA 633/2023 | AY 2014–15 | No Substantial Question of Law
Facts of the Case
The
Revenue preferred an appeal before the Delhi High Court against the ITAT
order.
The
dispute pertains to Assessment Year 2014–15.
During
the hearing, it was acknowle...
PR. Commissioner of Income Tax–3 vs Devata Tradelink Ltd. (Delhi High Court) – Section 14A Disallowance Cannot Exceed Exempt Income | AY 2008-09
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), which
deleted disallowance made under Section 14A.
The assessee earned exempt income of...
Commissioner of Income Tax (International Taxation)-3 vs Ricardo U.K. Limited – No Further Profit Attribution to PE When Arm’s Length Remuneration Paid [Section 9, India-UK DTAA]
Facts of the
CaseThe case pertains to Assessment Year 2016–17. The
respondent, Ricardo U.K. Limited, is a company incorporated in the United
Kingdom and is a tax resident of the UK under Article 4 of the India-UK Do...
Deepak Modi vs Assistant Commissioner of Income Tax Circle 46(1) & Anr. | Delhi High Court | Reassessment u/s 148A(d) Set Aside for Violation of Natural Justice (No Personal Hearing)
Facts of the
CaseThe present writ petition pertains to Assessment
Year 2019–2020, wherein the petitioner, Deepak Modi, was subjected to
reassessment proceedings on allegations of availing accommodation entries
thro...
Shourya Estates Pvt. Ltd. vs Income Tax Officer, Ward 23(2), New Delhi & Anr. (Delhi High Court) – Reopening of Assessment under Section 148 Quashed
Facts of the
CaseThe present writ petition pertains to Assessment
Year (AY) 2011–12. The petitioner, Shourya Estates Pvt. Ltd. (SEPL), challenged
the legality of a notice dated 31.03.2018 issued under Section 148 of...