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Rampgreen Solutions Pvt. Ltd. v. Commissioner of Income Tax: Sub-Classification within ITeS Segments Imperative for Arm’s Length Price (ALP) Determination under Section 92C
Facts of the Case
Corporate
Profile and Transactions: The Assessee, Rampgreen
Solutions Pvt. Ltd., operates as a wholly owned subsidiary of vCustomer,
USA (its Associated Enterprise, or 'AE'). Registe...
Commissioner of Income Tax-I vs M/s Cotton Naturals (I) Pvt. Ltd.: LIBOR as Benchmark for Foreign Currency Loans under Transfer Pricing
Facts of the
CaseThe present appeal was filed by the Revenue under
Section 260A of the Income Tax Act, 1961 against the order passed by the Income
Tax Appellate Tribunal relating to Assessment Year 2007-08.The respond...
Pr. Commissioner of Income Tax-09 v. Tupperware India Pvt. Ltd. | Validity of Reassessment under Section 147/148 in the Absence of Fresh Tangible Material
Facts of the Case
Return
Filing: The Respondent Assessee (Tupperware India
Pvt. Ltd.) filed its return of income for Assessment Year (AY) 2003-04 on
December 2, 2003, declaring a loss of Rs. 96,19,890...
Commissioner of Income Tax Delhi-IV vs Daikin Air-Conditioning India Pvt. Ltd. | Technical Know-how Fee Held as Revenue Expenditure u/s 37(1) of Income Tax Act
Facts of the
CaseThe assessee, Daikin Air-Conditioning India Pvt.
Ltd., filed its return for AY 2005-06 declaring business income. During
assessment, the Assessing Officer made an addition of ₹43.75 lakhs on a...
Pr. Commissioner of Income Tax-5 vs. Le Passage to India Tours & Travels Pvt. Ltd.: Analysis of Fee for Technical Services under Section 40(a)(i)
Facts of the CaseThe Revenue (Appellant) challenged an order dated December 19,
2014, passed by the Income Tax Appellate Tribunal (ITAT) concerning the
Assessment Years (AYs) 2007-08 and 2008-09. The Assessing Officer ...
Commissioner of Income Tax-5 vs JCDecaux Advertising India Pvt. Ltd. – Allowability of Business Expenditure after Setting Up of Business under Sections 3 and 4 of the Income-tax Act, 1961 | Delhi High Court
Facts of the CaseThe
assessee, JCDecaux Advertising India Pvt. Ltd., was incorporated in
April 2005 for carrying on the business of out-of-home advertising, including
street furniture advertising, billboards, and tran...
Pr. Commissioner of Income Tax-6 v. Minda Acoustic Ltd. [2015:DHC:11381-DB]: Scope of Appellate Jurisdiction under Section 260A of the Income Tax Act, 1961
Facts of the CaseThe Revenue (Appellant) filed two appeals under Section 260A
of the Income Tax Act, 1961, challenging a common order passed by the Income
Tax Appellate Tribunal (ITAT) regarding the Assessment Year (AY...
Riddhi Promoters Pvt. Ltd. vs Commissioner of Income Tax-7 (Delhi High Court) – Addition under Section 68 on Unexplained Share Capital | Scope of Identity, Genuineness & Creditworthiness
Facts of the
CaseThe assessee company received ₹24 lakhs as share
capital from six share applicants. The return was originally processed
under Section 143(1). Thereafter, the Revenue reopened the assessment un...
Aroon Purie vs Commissioner of Income Tax | Delhi High Court | Taxability of Journalism Award under Section 10(17A), Section 2(24), Income Tax Act, 1961
Facts of the
CaseThe assessee, Aroon Purie, was serving as
Editor-in-Chief of India Today and deriving income from salary,
interest, dividend, and property.During the relevant assessment year, the assessee
received â...
Commissioner of Income Tax-VI vs Wings Pharmaceuticals Pvt. Ltd. – Section 80-IC Deduction on Baddi Unit, Old vs New Machinery Ratio & Alleged Accommodation Bills | Delhi High Court
Facts of the CaseThe Revenue filed appeals before the Delhi High Court under
Section 260A of the Income-tax Act against the common order passed by the
Income Tax Appellate Tribunal (ITAT) for Assessment Years 2006-07, ...