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Director of Income Tax vs. M/s McDonald’s Corporation: Validity of Reassessment Under Section 147 Based on "Change of Opinion" When Primary Facts Are Disclosed
acts of the Case
The
Arrangement: The assessee, McDonald’s Corporation (USA),
entered into a Master Licensing Agreement (MLA) on January 1, 1996, with
McDonald’s India Private Limited (MIPL). Unde...
Convergys Customer Management vs. Assistant Director of Income Tax: Prima Facie Belief of Business Connection & Permanent Establishment Under Section 147/148
Facts of the Case
The
Parties: The petitioner, Convergys Customer
Management, is a company incorporated in the USA engaged in providing
worldwide business process outsourcing (BPO) services. It operat...
The Commissioner of Income Tax-V vs. Orient Craft Ltd.: Validity of Reassessment Under Section 147 Post Section 143(1) Intimation Absent Tangible Material
Facts of the Case
Assessee
Profile & Return Filing: The assessee, a 100%
export-oriented company, filed its return of income for the Assessment
Year (AY) 2002-03 on October 31, 2002, declaring a t...
The Institute of Chartered Accountants of India (ICAI) & Anr. vs Director General of Income Tax (Exemptions), Delhi & Ors. – Exemption under Section 10(23C)(iv), Charitable Purpose under Section 2(15), Coaching Activities and Tax Exemption Eligibility
Facts
of the Case
ICAI was constituted under the
Chartered Accountants Act, 1949 as a statutory body for regulating the
profession of Chartered Accountants in India.
ICAI had historically been granted
...
Commissioner of Income Tax vs. Maruti Suzuki India Ltd. (2012:DHC:7465-DB) Alternative Title for SEO: Commissioner of Income Tax vs. Maruti Suzuki India Ltd. | Allowability of Excise PLA Deposits under Section 43B of Income Tax Act
Facts of the Case
Assessee
Profile: The respondent/assessee, Maruti Suzuki India
Ltd., is a prominent automobile manufacturer.
Regulatory
Requirement: To clear manufactured vehicles and goods
...
Meinhardt Singapore Pte Ltd. vs. Assistant Director of Income Tax, Circle 3(1), International Taxation, New Delhi – Reassessment Proceedings under Section 44D and 115A of the Income Tax Act
Facts of the
Case:
The petitioner operated through a branch in India providing
consultancy services for NHAI road projects.
A sub-consultancy agreement was entered with M/s Quest
International Cons...
GALILEO NEDERLAND BV Vs. ASSISTANT DIRECTOR OF INCOME TAX: Dismissal of Income Tax Appeals with Liberty to Revive Post-Section 254(2) Rectification Proceedings Before ITAT
Facts of the Case
The
appellant, Galileo Nederland BV, filed four appeals (ITA Nos.
655/2012, 657/2012, 658/2012, and 660/2012) against a common order passed
by the Income Tax Appellate Tribunal (ITAT...
Meinhardt Singapore Pte Ltd. vs. Assistant Director of Income Tax, Circle 3(1), International Taxation, New Delhi | Sections 44D & 115A
Facts of the
Case
Meinhardt Singapore Pte Ltd., a Singapore-based company with a
branch office in India, provided technical consultancy services to the
National Highway Authority of India (NHAI) unde...
Escorts Heart Institute & Research Centre vs. Commissioner of Income Tax (Central) : Validity of Reassessment Notices u/s 147/148 tracking Past Accumulated Income u/s 11(3) read with Section 10(21)
Facts of the Case
Assessee
Status: The petitioner is a scientific research
society approved under Section 35(1)(ii) of the Income Tax Act, 1961,
specializing in research related to coronary diseases. ...
Commissioner of Income Tax vs M/s. Ganapati Finance Ltd.: Depreciation on Leased Assets under Section 32 of the Income Tax Act, 1961
Facts of the
Case:The appellant, Commissioner of Income Tax (CIT),
challenged the Tribunal’s allowance of depreciation claims by M/s. Ganapati
Finance Ltd. on two categories of leased assets during the assessment ye...