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Commissioner of Income Tax-I vs. M/s Cotton Naturals (I) Pvt. Ltd. | Arm's Length Interest Rate Determination under Section 92C of Income Tax Act – Delhi High Court Rules LIBOR/International Rates Applicable for Foreign Currency Loans to Associated Enterprises Over Domestic Prime Lending Rate (PLR).
Facts of the Case
The
Assessee: The respondent-assessee, M/s Cotton
Naturals (I) Pvt. Ltd., is an Indian company engaged in manufacturing and
exporting rider apparel (such as riding jackets, boots, an...
The Commissioner of Income Tax Delhi-IV v. Daikin Air-Conditioning India Pvt. Ltd. (Under Section 260A of the Income Tax Act, 1961)
Facts of the Case
Assessee's
Income Profile: For the Assessment Year (AY) 2005-06, the
respondent-assessee reported a business income of ₹81,772,968/-.
Acquisition
History: The assessee had acqui...
Riddhi Promoters Pvt. Ltd. vs. Commissioner of Income Tax-7: Burden of Proof and Share Capital Additions under Section 68
Facts of the Case
Assessee
Profile & Filing: The assessee is a private limited
company incorporated on March 11, 2003. For the relevant Assessment Year,
its return was initially processed under Se...
Aroon Purie Vs. Commissioner of Income Tax: Taxability of Professional Excellence Awards under Section 2(24) and Section 10(17A) of the Income Tax Act, 1961
Facts of the Case
The
Appellant, Mr. Aroon Purie, was the Editor-in-Chief of the prominent
English magazine India Today during the previous year relevant to the
Assessment Year 1991-92.
In
hi...
Commissioner of Income Tax-II v. McKinsey Knowledge Centre India Pvt. Ltd.: Section 10A Deduction for IT-Enabled Back-Office Services and the Principle of Consistency
Facts of the Case
The
Assessee Company, incorporated on February 15, 1999, is a wholly owned
subsidiary of McKinsey Holdings Inc.
The
Assessee was set up as a unit under the Software Technology Par...
Krishak Bharati Coop. Ltd. vs. Commissioner of Income Tax: Scope of Rectification Under Section 154 on Debatable Deductions
Facts of the CaseThe appellant, Krishak Bharati Coop. Ltd., filed its income
tax return for the Assessment Year 1992–93, claiming a business expenditure
deduction of ₹91,32,404 under Section 43B of the Income Tax A...
Vatika Limited vs. Commissioner of Income Tax: Concurrent Factual Findings on Undisclosed Real Estate Income Under Section 132
Facts of the Case
Search
and Seizure: A search and seizure operation under Section
132 of the Income Tax Act was conducted at the business premises of the
appellant, Vatika Limited (formerly Vatika La...
Commissioner of Income Tax XIII vs Bharat Bhushan Jain & Connected Assessees – Delhi High Court on Section 68 Addition, Accommodation Entries, Burden of Proof and Unexplained Cash Credits | ITA Nos. 669/2009 to 1326/2010
Facts of the CaseThe Revenue preferred a batch of appeals against several
assessees on the allegation that amounts received by them represented
accommodation entries and unexplained cash credits liable to addition unde...
Shravan Gupta vs. Assistant Commissioner of Income Tax: Prosecution for Willful Failure to Produce Foreign Bank Accounts Under Section 276D of the Income Tax Act
Facts of the Case
Voluntary
Disclosure: On November 17, 2011, the petitioner
voluntarily disclosed a foreign bank account held with HSBC Private Bank
in Geneva, Switzerland, to the Director of Income ...
Director of Income Tax (International Taxation) vs GE Engine Services Distribution LLC – Delhi High Court | Sections 9(1)(vii), 44BB & Permanent Establishment Issues under Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against various GE group entities, including GE Engine
Services Distribution LLC, concerning the taxability of receipts ear...