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BLB Limited vs. Assistant Commissioner of Income Tax: Analysis of Reassessment Proceedings and the "Change of Opinion" Doctrine
Facts of the Case
The petitioner, BLB Limited, filed its income tax return for
the Assessment Year (AY) 2003-04, declaring an income under Section 115JB of
the Income Tax Act, 1961. During the original scrutiny asse...
Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of Rule 8D and Section 14A
Facts of the CaseThe case consolidated three separate income tax appeals (ITA
277/2009, 460/2009, and 949/2009) concerning the assessment years 2004-05,
2000-01, and 2002-03. The dispute involved the Oriental Bank of C...
Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of the Non-Retrospective Nature of Rule 8D and the Application of Section 14A of the Income Tax Act
Facts of the CaseThe appeals pertained to the assessment years 2000-01,
2002-03, and 2004-05 concerning the respondent, Oriental Bank of Commerce. The
dispute arose regarding the application of Rule 8D of the Income Ta...
Commissioner of Income Tax vs. M/S DCM Shriram Consolidated Ltd: Applicability of Rule 8D and Mechanism of Disallowance Under Section 14A of the Income Tax Act, 1961
Facts of the Case
Nature
of Appeal: The Appellant (Revenue) filed an appeal
under Section 260A of the Income Tax Act, 1961, directed against the order
of the Income Tax Appellate Tribunal (Tribunal) d...
M/s Genpact India vs. Assistant Commissioner of Income Tax: Legality of Unilateral Tax Refund Adjustments Under Section 245 and the Computational Treatment of Telecommunication Expenses for Deductions Under Section 10A of the Income Tax Act, 1961
Facts of the Case
The
petitioner, M/s Genpact India, is engaged in rendering IT-enabled services
and had established undertakings under the Software Technology Park Scheme
(STPS).
For
the Ass...
Atsushi Yoshida vs. Assistant Commissioner of Income Tax: Validity of Reopening Assessment Under Section 147 Post Revised Return and Form 16 Alterations
Facts of the Case
Employment
& Compensation: The petitioners were employees of M/s
Tokio Marine and Nichido Fire Inc. Limited and were paid a tax-free salary
in India, meaning the income tax compo...
Atsushi Yoshida Vs Assistant Commissioner of Income Tax: Scope of Income Tax Reopening Under Section 147/148 Post Expiry of Section 143(3) Scrutiny Timelines
FACTS OF THE CASE
The
petitioners were expatriate employees of M/s Tokio Marine and Nichido Fire
Insurance Company Limited.
Under
the specific terms of their employment contracts, they were paid a
...
Atsushi Yoshida vs. Assistant Commissioner of Income Tax (With Companion Petitions) Income Tax Act, 1961: Section 143(1), Section 143(2), Section 143(3), Section 133(6), Section 147, and Section 148.
Facts of the Case
The
Assessees: The petitioners—Atsushi Yoshida, Yasunobu
Fukuda, Shunzo Nagahama, Mazahiro Ogawa, and Toshiyuki Nakai—were
employees of M/s Tokio Marine and Nichido Fire Inc. Lim...
Atsushi Yoshida Vs. Assistant Commissioner of Income Tax (and Connected Petitions) – Validity of Reopening Assessment Under Section 147/148 Following Section 143(1) Intimation in Cases of Revised Return and Salary Grossing-Up Claims
Facts of the Case
Employment
Terms: The five petitioners were expatriate
employees of M/s Tokio Marine and Nichido Fire Inc. Limited. Under
their specific terms of employment, they were paid a contrac...
ATSUSHI YOSHIDA & ORS. Vs. ASSISTANT COMMISSIONER OF INCOME TAX Reopening of Assessment under Section 147/148 | Validity of Notice after Expiry of Section 143(2) Timeline | Processing under Section 143(1) vs. Regular Assessment
Facts of the Case
Employment
and Salary Terms: The petitioners were employees of M/s
Tokio Marine and Nichido Fire Inc. Limited and were paid tax-free salaries
in India, with the income tax component ...