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GE Nuovo Pignone S.P.A. Vs Commissioner of Income Tax (International Taxation), Delhi – ITAT’s Failure to Adjudicate Grounds on Installation PE, Attribution of Income & Fees for Technical Services under Sections 254(2) and 260A of the Income Tax Act
Facts of the
CaseGE Nuovo Pignone S.P.A., the assessee, filed
multiple appeals challenging a common order passed by the ITAT for Assessment
Years 2001–02 to 2008–09.Before the ITAT, the assessee had specifically
...
Commissioner of Income Tax v. Vasavi Pratap Chand & Sidharth Pratap Chand | Delhi High Court | Capital Gains on Joint Development Agreement | Section 2(47), Section 48, Section 55 Income Tax Act & Section 7(4) Wealth Tax Act
Facts of the CaseThe dispute arose from the sale of developed flats constructed
on ancestral land situated at 6, Aurangzeb Road, New Delhi. The property
originally belonged to the family and was subsequently partitione...
Pr. Commissioner of Income Tax (Central)-3 & Anr. vs Ram Narain Jindal | Delhi High Court | Section 153A Income Tax Act | No Addition Without Incriminating Material During Search Proceedings
Facts of the CaseThe case involves the PR. Commissioner of Income Tax (Central)-3
challenging the Tribunal's ruling that set aside additions made under Section
153A of the Income Tax Act. The Tribunal applied the decis...
Pr. Commissioner of Income Tax–6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on Effect of IBC Moratorium on Pending Income Tax Appeals under Sections 14, 238 & 7 of Insolvency and Bankruptcy Code, 2016
Facts of the CaseThe Revenue Department had filed multiple income tax appeals
before the Delhi High Court challenging orders passed by the Income Tax
Appellate Tribunal in relation to the tax liabilities of Monnet Ispa...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT Order Set Aside for Non-Adjudication of Installation PE, Attribution of Income & Fees for Technical Services under Sections 260A and 254(2) of the Income Tax Act
Facts of the
CaseThe assessee, GE Nuovo Pignone S.P.A., filed
appeals before the Delhi High Court challenging a common order passed by the
ITAT for Assessment Years 2001-02 to 2008-09. The grievance of the assessee wa...
Commissioner of Income Tax vs. Vasavi Pratap Chand & Sidharth Pratap Chand (Delhi High Court) – Capital Gains Computation on Joint Development Agreement, Fair Market Value under Section 55, and Non-Adoption of Wealth Tax Valuation under Section 7(4) of Wealth Tax Act
Facts of the CaseThe property situated at 6, Aurangzeb Road, New Delhi,
originally acquired in 1947, became part of a Hindu Undivided Family (HUF) and
was later partitioned among co-owners in equal shares. To overcome ...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT Order Set Aside for Non-Adjudication of Permanent Establishment (PE), Fees for Technical Services (FTS) and Attribution Issues under Sections 260A & 254(2) of the Income Tax Act, 1961
Facts of the
CaseThe assessee filed appeals before the ITAT
challenging tax treatment on several grounds involving installation Permanent
Establishment, attribution of profits, and taxability of technical service
inc...
Pr. Commissioner of Income Tax-6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on IBC Moratorium over Income Tax Appeals under Sections 14, 238 & 7 of Insolvency and Bankruptcy Code, 2016
Facts of the CaseThe Revenue Department, through the Principal Commissioner
of Income Tax, filed multiple appeals before the Delhi High Court challenging
the order passed by the Income Tax Appellate Tribunal (ITAT) con...
Pr. Commissioner of Income Tax-18 vs N. S. Software (Firm) | Delhi High Court on Scope of Additions in Section 153A Assessments in Light of Kabul Chawla Principle
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court concerning Assessment Years 2005-06 and 2006-07 against the
respondent assessee, N. S. Software (Firm). The dispute arose from assessment...
H.T. Media Limited Vs. Principal Commissioner of Income Tax-IV, New Delhi | Delhi High Court | Section 14A read with Rule 8D of Income Tax Rules | Disallowance of Interest & Administrative Expenditure on Exempt Income
Facts of the CaseH.T. Media Limited, engaged in printing and publishing
newspapers and periodicals, filed its return for AY 2008-09 declaring taxable
income.During the relevant assessment year:
The
assess...