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Chryscapital Investment Advisors (India) Pvt. Ltd. vs Deputy Commissioner of Income Tax Transfer Pricing – Comparable Selection – Super Normal Profits – Multiple Year Data – Bonus Disallowance under Section 36(1)(ii)
Facts
of the CaseThe assessee, Chryscapital Investment Advisors (India)
Pvt. Ltd., was engaged in providing investment advisory
services to its Associated Enterprises (AEs) on a cost-plus mark-up basis.
During AY 200...
Commissioner of Income Tax-II vs McKinsey Knowledge Centre India Pvt. Ltd. | Delhi High Court | Section 10A Deduction on IT Enabled Services & Transfer Pricing Comparables
Facts of the CaseThe assessee, McKinsey Knowledge Centre India Pvt.
Ltd., was engaged in providing support services including export of computer
software, IT-enabled services, data processing, customization of data,
b...
Commissioner of Income Tax-XIII vs Vaish Associates – Partner Remuneration Allowable u/s 40(b)(v) and Contribution to Professional Body Allowed as Business Expenditure u/s 37(1) | Delhi High Court
Facts of the CaseThe assessee, Vaish Associates, a partnership firm engaged in
the legal profession at New Delhi and Mumbai, had executed a
retirement-cum-partnership deed effective from 1 April 2006. Clause 6(a) of th...
Krishak Bharti Coop. Ltd. vs Commissioner of Income Tax (Delhi High Court) – Scope of Rectification under Section 154 and Deduction under Sections 43B & 80-I of the Income-tax Act
Facts of the
CaseThe assessee, Krishak Bharti Cooperative Ltd.,
claimed business expenditure of ₹91,32,404 under Section 43B of the Income-tax
Act towards contribution made to the Cooperative Education Fund under Se...
Commissioner of Income Tax (Central)-I vs MGF Automobiles Ltd. – Addition under Sections 153A & 72A Invalid in Absence of Incriminating Material Found During Search | Delhi High Court
Facts of the CaseThe Respondent-Assessee, MGF Automobiles Ltd., was engaged in
the business of automobile dealership and service station operations. During
Assessment Year (AY) 2004-05, the assessee entered into an ama...
Commissioner of Income Tax-I vs Accession Buildwell (P) Ltd. – Taxability of Interest on Fixed Deposits and Allowability of Business Expenditure under the Income-tax Act
Facts of the Case
The assessee
company was engaged in the business of builders and developers.
It raised funds
through debentures for business expansion and land acquisition.
As per the
Debenture ...
Commissioner of Income Tax, Central-II vs. Divine Infracon Pvt. Ltd. | Section 68 & Section 153A of Income Tax Act | Revenue Cannot Challenge Final CIT(A) Findings Without Filing Appeal | Delhi High Court
Facts of the CaseThe assessee, Divine Infracon Pvt. Ltd., filed its return of
income for Assessment Year 2008-09 declaring total income of ₹3,84,027.
Subsequently, search and seizure operations were conducted on 14 S...
Pr. Commissioner of Income Tax-08 vs Staunch Marketing Pvt. Ltd. | Mandatory Notice under Section 143(2) after Reassessment Proceedings under Section 148 – Delhi High Court
Facts
of the CaseThe Revenue preferred
an appeal under Section 260A of the Income Tax Act, 1961 against the order of
the Income Tax Appellate Tribunal (ITAT) concerning Assessment Year 2003–04.
The Assessing Office...
Shri Lal Mahal Limited vs Commissioner of Income Tax (Delhi High Court) – Section 80HHC Deduction on DEPB Benefits, Retrospective Amendment & Export Incentive Tax Relief
Facts
of the CaseThe assessee, Shri Lal
Mahal Limited, engaged in export business activities, claimed deduction under
Section 80HHC of the Income Tax Act in respect of export profits, including
benefits arising from ...
Commissioner of Income Tax, Central-II vs. Divine Infracon Pvt. Ltd. | Scope of Section 153A Assessment and Finality of CIT(A) Findings under Section 68 of the Income Tax Act
Facts of the Case
The
assessee, Divine Infracon Pvt. Ltd., filed its return of income for
Assessment Year 2008-09 declaring total income of ₹3,84,027/-.
Subsequently,
a search and seizure operatio...