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Commissioner of Income Tax (Central), New Delhi vs M/s Sarb Consulate Marine Products Pvt. Ltd.: Validity of Block Assessment Limitation Period Under Section 158BE vs Artificial Extension of Search and Seizure Operations Through Dummy Panchnama Under Section 132 of the Income Tax Act, 1961
Facts of the Case
The
Search Action: The Respondent-Assessee, an entity engaged
in fishing activities on the high seas, was subjected to a search and
seizure operation under Section 132 of the Income ...
Commissioner of Income Tax, Delhi-VIII, New Delhi vs. Sawhney Exports (2007) | Allowance of Bad Debts Under Section 36(1)(vii) of the Income Tax Act, 1961: Whether Prior or Post-Facto Reserve Bank of India (RBI) Approval is Mandatory for Writing Off Foreign Exchange Bad Debts in the Books of Accounts
Facts of the Case
The
Assessee (Sawhney Exports) is an export house engaged in the business of
exporting garments and receiving payments in foreign exchange.
For
the Assessment Year (AY) 1997-98, th...
Commissioner of Income Tax vs Divine Leasing & Finance Ltd., General Exports & Credits Ltd. & Lovely Exports (P) Ltd. – Section 68 Share Capital Addition, Burden of Proof and Unexplained Cash Credits (Delhi High Court)
Facts of the CaseThe Revenue filed a batch of appeals challenging
concurrent findings of the Commissioner of Income Tax (Appeals) [CIT(A)] and
the Income Tax Appellate Tribunal (ITAT), both of which had deleted additio...
Commissioner of Income Tax, Delhi-VIII v. Shri Prem Nath Nagpal: Legality of Block Assessment Additions Under Section 158BC Based Solely on DVO Reference in the Absence of Seized Incriminating Material and the Interpretation of Undisclosed Income Under Chapter XIV-B of the Income Tax Act, 1961
Facts of the Case
Search
Operations: A search and seizure operation under Section
132 of the Income Tax Act, 1961, was conducted at the residential premises
of the Assessee on December 17, 1999.
Re...
Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd. (ITA No. 1531/2006) – Interpretation of 'Manufacture' under Section 80IA of the Income Tax Act, 1961: Delhi High Court Judgment
Facts of the Case
Parties: The
Appellant is The Commissioner of Income Tax-V, New Delhi, and the
Respondent is M/s Oracle Software India Ltd..
Assessment
Year: The dispute pertains to the Assessmen...
Commissioner of Income Tax vs P.H.I. Seeds India Ltd. (2006) – Penalty under Section 271(1)(c) Cannot Be Levied for Bona Fide Claim Based on Debatable Interpretation of Law
Facts of the CaseThe assessee, P.H.I. Seeds India Ltd., was engaged
in agricultural activities and earned interest income from Fixed Deposit
Receipts (FDRs) amounting to Rs. 12,07,217, which was assessable under the he...
The Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd. (2007) | ITA No. 785 of 2006 (Consolidated with ITA No. 641 of 2006) – Delhi High Court Judgement on Section 80IA Manufacture Qualification for Software Duplication and Section 40(a)(i) Deferral Allowability upon TDS Payment
Facts of the Case
The
Assessee, M/s Oracle Software India Ltd., is a 100% subsidiary of Oracle
Corporation, USA. It is engaged in developing, designing, marketing, and
importing computer software.
...
Commissioner of Income Tax, Delhi-XVII vs Prasar Bharti (Broadcasting Corporation of India) – TDS on Television Programme Production Payments: Section 194C vs Section 194J | Delhi High Court
Facts of the
CaseThe respondent, Prasar Bharti (Broadcasting
Corporation of India), made payments to producers engaged for producing
television programmes under the “commissioned category.” While making such
paym...
Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd. (2007) | Interpretation of Section 40(a)(i) Royalty Expenses with Pre-Year Tax Deductions at Source (TDS) and Duplication of Software Master Copies as Eligible Manufacturing Activity under Section 80-IA of the Income Tax Act, 1961: A Comprehensive Case Brief on Corporate Deductions and Fiscal Compliance Precedents
Facts of the Case
Corporate
Structure: The Respondent/Assessee (M/s Oracle Software
India Ltd.) is a 100% wholly-owned subsidiary of Oracle Corporation, USA.
It was incorporated to develop, produce, m...
The Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd.: High Court of Delhi on Section 40(a)(i) Tax Deduction at Source (TDS) Compliance Timelines and Section 80IA Deductions for Software Duplication as a Manufacturing Activity
Facts of the Case
The
Respondent/Assessee (M/s Oracle Software India Ltd.) is a 100%
subsidiary of Oracle Corporation, USA, engaged in developing, designing,
producing, marketing, distributing, and im...