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Maruti Suzuki India Ltd. & Another vs Additional Commissioner of Income Tax & Another – Reassessment under Sections 147/148 of Income Tax Act on Royalty Expenditure, Change of Opinion and Requirement of Tangible Material
Facts of the CaseMaruti Suzuki India Ltd. was engaged in the business of
manufacture, purchase and sale of automobiles. For Assessment Year 2005–06, the
company filed its return declaring total income and claimed ded...
Director of Income Tax vs. M/s Nokia Networks OY – Offshore Supply, Permanent Establishment (PE), Software Royalty & Taxability under Section 9 of the Income Tax Act | Delhi High Court
Facts of the CaseNokia Networks OY, incorporated in Finland, was engaged in
manufacturing advanced GSM telecommunications systems and equipment.During Assessment Years 1997–98 and 1998–99:
Nokia
maintained a...
Commissioner of Income Tax vs Bharat Heavy Electricals Limited (BHEL) – Deduction for Wage Revision Provision, Tax-Free Bond Interest Exemption, Donation Expenditure under Section 37(1), and Section 80HHB Project Loss Set-off | Delhi High Court
Facts of the CaseBharat Heavy Electricals Limited (BHEL), a public sector
undertaking, claimed deductions relating to provisions created for anticipated
wage revisions based on previous experience, Pay Commission repor...
CIT v. Bharat Heavy Electrical Limited (BHEL) – Allowability of Wage Revision Provision, Tax-Free Bond Interest Exemption, Donation Deduction under Section 37(1), and Project-wise Deduction under Section 80HHB | Delhi High Court
Facts of the CaseBHEL, a public sector undertaking, claimed various deductions
and exemptions under the Income Tax Act for the relevant assessment years.
BHEL
made provisions towards wage revision liabilities ba...
Commissioner of Income Tax (CIT) vs. Bharat Heavy Electricals Limited (BHEL) – Delhi High Court on Deduction under Section 80HHB and Provision for Anticipatory Loss under the Income Tax Act, 1961
Facts of the CaseBHEL, a public sector engineering and manufacturing
enterprise, had claimed deduction benefits under Section 80HHB in relation to
income earned from overseas projects. During assessment proceedings, th...
Commissioner of Income Tax vs Bharat Heavy Electrical Limited (BHEL) – Delhi High Court on Recall of ITAT Order and Scope of Section 254(2) of the Income Tax Act
Facts of the Case
The
Revenue challenged the Tribunal's order which had allowed a provision for
anticipated loss in favour of Bharat Heavy Electrical Limited (BHEL).
The
issue arose from assessment...
Commissioner of Income Tax vs Bharat Heavy Electricals Limited (BHEL) – Deduction under Section 80HHB, Computation of Eligible Income and Treatment of Anticipatory Loss | Delhi High Court
Facts of the CaseBharat Heavy Electricals Limited (BHEL), a public sector
undertaking engaged in engineering and infrastructure activities, claimed
deductions under Section 80HHB of the Income Tax Act with respect to p...
Commissioner of Income Tax, Delhi vs Telecom Finance (India) Ltd.: Whether Lease–Sublease Arrangement and Renovation Expenditure Constituted Genuine Business Transactions or Tax Avoidance Device under Sections 30, 32 and 37 of the Income Tax Act
Facts of the Case
The
assessee, Telecom Finance (India) Ltd., was engaged in the business of
leasing, hire-purchase and finance activities.
During
Assessment Year 1997–98, the assessee entered in...
Commissioner of Income Tax, Delhi vs. Telecom Finance (India) Section 30Ltd. – Deductibility of Leasehold Renovation Expenditure, Genuineness of Lease/Sub-Lease Transactions and Depreciation Claim under the Income Tax Act
Facts of the CaseThe assessee, Telecom Finance (India) Ltd., was engaged in the
business of leasing, hire purchase, and finance activities. During Assessment
Year 1997–98, the assessee entered into a lease agreement ...
Punjab and Sind Bank vs Commissioner of Income Tax & Another – Depreciation on Securities Held as Stock-in-Trade, Amortization of Premium on Investments and Classification of Banking Securities under Sections 143(3), 154, 36 & 145 of the Income Tax Act | Delhi High Court
Facts of the CasePunjab and Sind Bank, a statutory banking corporation and
wholly owned Government of India undertaking, filed its income tax return for
Assessment Year 1996–97 declaring a loss.During assessment proc...