Blog Categories
Subscribe to Newsletter
Join our subscribers list to get the latest Tax Updates and Opportunities.
Knowledge Portal
Click here to explore deep insights, FAQs, and comprehensive tax guides.
Explore Now
Delhi High Court | ITA Nos. 371 to 381 of 2005 | Judgment dated 31.08.2017 Rectification under Section 154 cannot be used as Review of Earlier Appellate Order – Penalty under Section 271C not sustainable where reasonable cause for non-deduction of TDS on expatriate salary is established
Facts of the CaseThe assessee, Denso India Limited, engaged in manufacturing
operations in India, had expatriate technicians deputed by its Japanese parent
company. These employees received part of their salary in Indi...
Pr. Commissioner of Income Tax-9 vs WSP Consultants India Pvt. Ltd. | Delhi High Court on Transfer Pricing Comparables under Section 260A read with Section 92C of the Income Tax Act, 1961
Facts of the CaseThe assessee, WSP Consultants India Pvt. Ltd., is
a subsidiary of a Cyprus-based company engaged globally in design, engineering,
and management consultancy services in infrastructure and environ...
Pr. Commissioner of Income Tax-9 vs M/s Times Internet Ltd. | Delhi High Court | Section 37(1), Section 260A Income Tax Act | Allowability of Business Expenditure After Sale of Business Vertical & Website Development Expenditure as Revenue Expenditure
Facts of the
Case
The assessee had transferred certain business segments including
Medianet and content selling business.
Despite such transfer, the assessee continued to claim business
expenditure comp...
M/s Fiberfill Engineers vs Deputy Commissioner of Income Tax (Delhi High Court) – Delay in Filing Return, Deduction under Section 80IC, Reassessment under Sections 147/148 and Condonation under Section 119(2)(b) of Income Tax Act, 1961
Facts of the CaseThe Petitioner, M/s Fiberfill Engineers, is a partnership firm
engaged in works contracts and manufacturing signages and fabricated structures
through its manufacturing unit situated at Sitarganj, Utta...
Ansal Housing & Construction Ltd. vs Assistant Commissioner of Income Tax & Deputy Commissioner of Income Tax | Taxability of Unsold Flats Held as Stock-in-Trade under Sections 22 & 23 of the Income Tax Act, 1961 | Delhi High Court
Facts of the CaseThe assessee, engaged in the business of real
estate development and construction, had completed certain residential and
commercial units which remained unsold and continued to be reflected as
s...
Commissioner of Income Tax vs Denso India Limited | Delhi High Court on Scope of Rectification under Section 154 and Penalty under Section 271C of Income Tax Act
Facts of the CaseDenso India Limited engaged expatriate technicians deputed
by its parent company in Japan for its manufacturing operations in India. The
Indian entity paid salary in India and provided accommodation, w...
Ansal Housing & Construction Ltd. vs Assistant Commissioner of Income Tax & Deputy Commissioner of Income Tax | Taxability of Unsold Flats Held as Stock-in-Trade under Sections 22 & 23 of the Income Tax Act, 1961 | Delhi High Court
Facts of the CaseThe assessee, engaged in the business of
construction and sale of residential and commercial properties, retained
certain flats as unsold inventory (stock-in-trade). These properties remained
in its p...
CIT vs Renu Constructions Pvt. Ltd. & Ankit Gupta | Delhi High Court on Validity of Section 153C Proceedings and Requirement of “Belonging To” Seized Documents under Income Tax Act
Facts of the CaseThe present batch of appeals arose from search and
seizure operations conducted in the BM Gupta Group cases. During the
course of the search, certain documents were seized by the Department. Based on
...
Taxability of Non-Compete Fee Received on Retirement – Whether Non-Compete Compensation Constitutes Capital Receipt or Revenue Receipt under Section 28(ii) of the Income-tax Act, 1961
Facts of the CaseThe Respondent-Assessee, Mrs. Tara Sinha, was serving
as the President of Tara Sinha McCann Erickson Pvt. Ltd. (TSME), a leading
advertising agency, and held 51% shareholding in the company. During
As...
Commissioner of Income Tax vs Denso India Limited (Delhi High Court) – Scope of Rectification under Section 154 vis-à-vis Review of Appellate Order and Penalty under Section 271C for Failure to Deduct TDS on Expatriate Salary
Facts of the CaseDenso India Limited, engaged in manufacturing operations,
had expatriate technicians deputed from its Japanese parent entity. These
employees received salary partly in India and partly in Japan.During ...