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Commissioner of Income Tax (International Taxation)-1, New Delhi vs Air India Ltd. (Delhi High Court, 2022) – Section 206AA vs DTAA | TDS on Non-Residents Without PAN
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 23.04.2021 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2013–14. The case involved payments made by ...
Pr. Commissioner of Income Tax-7, Delhi vs Telecommunications Consultants India Ltd. | Section 14A Disallowance Not Applicable in Absence of Exempt Income (Delhi High Court)
Facts of the Case
The
Revenue filed an appeal challenging the ITAT order dated 16 July 2021 for
AY 2011-12.
The
ITAT had deleted disallowance of ₹3,96,75,870/- made under Section 14A.
It
...
TRUEBLUE INDIA LLP vs DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 43-1 & ORS (Delhi High Court, 2022) – Refund Withholding under Section 241A Held Invalid
Facts of the
Case
The petitioner filed a writ petition challenging the order dated 15
June 2022 passed under Section 241A withholding refund.
The Income Tax Department had already processed the return and
...
PR. Commissioner of Income Tax vs. Shri Roop Kishore Madan (2022) – Delhi High Court | Section 260A | Unexplained Capital Addition Deleted
Facts of the Case
The
assessee, proprietor of M/s Rhea Distribution Company, introduced capital
amounting to ₹24,50,91,663.
The
Assessing Officer (AO) treated the same as unexplained due to lack ...
Principal Commissioner of Income Tax, Delhi-20 vs. Suman Agarwal | Section 153A & 68 Income Tax Act | No Addition Without Incriminating Material in Search Cases (Delhi High Court)
Facts of the
Case
A search and seizure operation under Sections 132/133A was
conducted on a third-party group (M/s K.R. Pulp & Papers Ltd.).
Statement of the Managing Director alleged routing of undisclos...
Principal Commissioner of Income Tax-3 vs M/s Amway India Enterprises (2022) – Delhi High Court | Transfer Pricing Adjustment on Royalty & ALP
Facts of the Case
The
assessee, engaged in direct selling through multi-level marketing,
filed its return for AY 2013-14 declaring income of ₹3,04,03,40,790.
Due
to international transactions wit...
PR. Commissioner of Income Tax-1, Delhi vs M/s Convergys India Services Pvt. Ltd. & Anr. (2022) – Transfer Pricing | ALP | Section 133(6) | Rule 10B | ITA 234/2022 (Delhi High Court)
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 22.11.2019 passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2012–13. The dispute pertains to
determinat...
PR. Commissioner of Income Tax Delhi-1 vs Arvind Kumar Arora (2022:DHC:3547-DB) – Section 41(1) Addition on Cessation of Liability Not Sustainable Where Liability Repaid
Facts of the CaseThe Revenue filed an appeal challenging the order of the
ITAT which upheld the deletion of an addition of ₹6,44,29,650 made by the
Assessing Officer under Section 41(1) of the Income Tax Act.The Asse...
M/s Expeditors International of Washington, Inc. vs Assistant Commissioner of Income Tax, Circle International Tax 1(2)(2), Delhi & Anr. (Delhi High Court, 2022)
Facts of the
CaseThe petitioner, M/s Expeditors International of
Washington, Inc., filed a writ petition challenging an order dated 14 July 2022
passed by the Income Tax Appellate Tribunal under Section 254 of the Inc...
Mahashian Di Hatti Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court, 2022) – Reassessment u/s 148A Set Aside for Lack of Proper Disclosure
Facts of the CaseThe present writ petition was filed challenging:
Notice
dated 18 May 2022 issued under Section 148A(b),
Order
passed under Section 148A(d), and
Subsequent
notice issued under Se...