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Commissioner of Income Tax vs Mentor Graphics (Noida) Pvt. Ltd. | Section 92C, Section 92CA & Rule 10B – Transfer Pricing, Arm’s Length Price and Arithmetic Mean Principle under TNMM
Facts of the
CaseMentor Graphics (Noida) Pvt. Ltd. was an Indian
company and a wholly owned subsidiary of IKOS Systems Inc., USA, engaged in
software development services and marketing support services for its parent
...
Pepsi Foods Pvt. Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court) – Invalid Assumption of Jurisdiction Under Section 153C Without Proper Satisfaction Note | Sections 153C, 132(4A) & 292C of Income Tax Act
Facts of the Case
A search and seizure operation under Section 132 of the Income Tax
Act was conducted on the Jaipuria Group on 27.03.2012.
During the course of search, certain documents were seized
alle...
Commissioner of Income Tax vs. M/s Ansal Properties & Industries Ltd. & M/s Ansal Housing & Construction Ltd. – Delhi High Court on Disposal of Connected Income Tax Appeals Following Earlier Binding Judgment | Sections under Income Tax Act
Facts of the
Case
Multiple income tax appeals were filed by the Commissioner of
Income Tax against various Ansal group entities including M/s Ansal
Properties & Industries Ltd. and M/s Ansal Housing &a...
Commissioner of Income Tax vs. M/s Ansal Properties & Industries Ltd. & Connected Matters – Applicability of Findings in Connected Income Tax Appeals | Delhi High Court | ITA Nos. 56/2001, 57/2001, 105/2001, 107/2001, 109/2001, 114/2001, 177/2001, 88/2002, 111/2003, 321/2003, 498/2003, 227/2004, 336/2004, 529/2004 & 212/2005
Facts of the
Case
A series of Income Tax Appeals had been filed by the Revenue before
the Delhi High Court against Ansal group entities.
The appeals covered multiple assessment disputes and involved
...
PepsiCo India Holdings Private Limited vs Assistant Commissioner of Income Tax & Another (2014:DHC:3930-DB) – Delhi High Court Clarifies Scope of Section 153C of Income Tax Act Regarding Seized Documents and “Belong To” Requirement
Facts of the CaseA search and seizure operation under Section 132(1)
of the Income Tax Act was conducted on the Jaipuria Group on 27.03.2012. During
the search, certain documents were allegedly found which, according t...
Commissioner of Income Tax Vs M/s Ansal Housing & Construction Ltd. / M/s Ansal Properties & Industries Ltd. – Taxability of Annual Letting Value (ALV) on Unsold Flats Held as Stock-in-Trade under Sections 22 & 23 of the Income Tax Act | Delhi High Court
Facts of the
Case
The assessees were engaged in the business of real estate
development and construction activities.
Certain flats and properties constructed by the assessees remained
unsold and were ref...
Commissioner of Income Tax vs. M/s Ansal Housing & Construction Ltd. & M/s Ansal Properties & Industries Ltd. – Delhi High Court | Disposal of Connected Income Tax Appeals Following Earlier Binding Judgment
Facts of the Case The Commissioner of Income Tax filed several appeals before the High
Court challenging orders passed in favour of the respondent companies in income
tax proceedings. The disputes pertained to ass...
PepsiCo India Holdings Pvt. Ltd. vs Assistant Commissioner of Income Tax & Anr. | Delhi High Court | Section 153C Income Tax Act | Meaning of “Belongs To” in Search & Seizure Proceedings
Facts of the CaseA search and seizure operation under Section 132(1)
of the Income Tax Act, 1961 was conducted on the Jaipuria Group on 27.03.2012.
During the course of the search, certain documents were allegedly foun...
PepsiCo India Holdings Pvt. Ltd. vs Assistant Commissioner of Income Tax & Anr. – Delhi High Court Clarifies Scope of Section 153C of the Income Tax Act on Seized Documents “Belonging To” Assessee
Facts of the CaseA search and seizure operation under Section 132(1)
was conducted on the Jaipuria Group on 27.03.2012. During the search, certain
documents were seized which, according to the Revenue, belonged to Peps...
PepsiCo India Holdings Pvt. Ltd. vs Assistant Commissioner of Income Tax & Anr. | Delhi High Court on Section 153C Proceedings, “Belongs To” Test & Invalid Satisfaction Note under Income Tax Act
Facts of the Case
A search and seizure operation under Section 132(1) of the Income
Tax Act was conducted on the Jaipuria Group on 27.03.2012.
During the search, certain documents were allegedly found wh...