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Director of Income Tax, New Delhi vs. AT Kearney Limited: Scope of Sections 44C, 80, and 254(2) regarding Head Office Expenses and Carry Forward of Losses for Foreign Entities with Indian Branches
Facts of the CaseThe respondent-assessee, AT Kearney Limited, is a foreign
entity operating an branch office in India. The Revenue preferred appeals
against the order of the Income-Tax Appellate Tribunal (ITAT) across ...
Ritz Theatre v. Income Tax Officer (Delhi High Court) – Validity of Reassessment Proceedings, Service of Notice under Section 148 and Scope of Remand by ITAT | ITA Nos. 978, 980, 981, 982 & 984 of 2010
Facts of the
CaseThe assessee, Ritz Theatre, filed returns for
Assessment Years 1990-91, 1991-92, 1992-93, 1995-96 and 1996-97. The returns
were filed pursuant to disclosures made under the Voluntary Disclosure of
In...
Director of Income Tax v. AT Kearney Limited: High Court of Delhi Affirmation on Section 80 Timely Loss Returns, the Restrictive Scope of Additional Grounds under Section 44C, and the Non-Invocation of Section 44D read with Section 115A
Facts of the CaseThe Revenue filed appeals against the orders of the Income-Tax
Appellate Tribunal (ITAT) concerning the assessee, M/s AT Kearney Limited, for
the relevant assessment years.
Undecided
Ground by ...
The Commissioner of Income Tax vs. M.G. Motors | Validity of Reassessment Under Section 147 of Income Tax Act 1961 Beyond Four Years Absent Failure to Disclose Material Facts | Delhi High Court Case Law ITA 1355/2010
Facts of the Case
Original
Assessment: The respondent-assessee, M.G. Motors, filed
its return of income for the Assessment Year 1997-1998 on October 31,
1997. The original assessment was thoroughly ex...
Marubeni India Pvt. Ltd. & Marubeni Corporation vs. Commissioner of Income Tax: Scope of Income Tax Appellate Tribunal’s (ITAT) Jurisdiction under Section 254(1) in Directing Deductions for Non-Appealed Assessment Years
Facts of the CaseThe appellant, Marubeni India Pvt. Ltd., was incorporated on
May 21, 1996, as a wholly-owned subsidiary of Marubeni Corporation, Japan. Upon
commencing business, the appellant took over the assets, lia...
Commissioner of Income Tax, Delhi II vs. Karl Storz Endoscopy India (P) Ltd.: Clarifying Tax Treatment of Salary Reimbursement vs. Technical Fees
Facts of the CaseThe dispute pertains to the Assessment Year 2001-02 regarding
the tax treatment of a payment amounting to ₹6,59,416 made by the
respondent-assessee, Karl Storz Endoscopy India (P) Ltd., to its parent...
Hacienda Farms Pvt. Ltd. vs. Commissioner of Income Tax: A Critical Analysis of Unexplained Cash Credits under Section 68 of the Income Tax Act, 1961
Facts of the CaseHacienda Farms Pvt. Ltd. (the "Appellant") filed its
income tax return for the Assessment Year 1996-97 with a declared income of
"nil". During the assessment proceedings conducted under Section
143(3)...
Ritz Theatre v. Income Tax Officer | Delhi High Court | Reassessment Proceedings under Sections 147 & 148 Cannot Be Reopened on Issues Already Finally Decided in Earlier Round of Litigation
Facts of the CaseThe assessee, Ritz Theatre, filed returns
for Assessment Years 1990-91, 1991-92, 1992-93, 1995-96 and 1996-97. The
Assessing Officer noticed that the assessee had made disclosures under the
Voluntary ...
Commissioner of Income Tax-IV, New Delhi vs. M/s Dharampal Premchand Ltd.: Leviability of Penalty under Section 271(1)(c) of the Income Tax Act, 1961 on Debatable Issues of Head Office and Unit-Wise Expense Allocations
Facts of the Case
Assessee
Profile and Manufacturing Activities: The
respondent-assessee, M/s Dharampal Premchand Ltd., was actively engaged in
the business of manufacturing flavored chewing tobacco a...
Commissioner of Income Tax vs. Assessee (Name Not Reflected in Order) | Delhi High Court Dismisses Revenue Appeal as Infructuous After Fresh Assessment Accepted Export Sales | ITA No. 971/2009
Facts of the
Case
The Revenue filed an appeal before the Delhi High Court against the
order passed by the Income Tax Appellate Tribunal.
During the proceedings, counsel for the assessee produced a copy of
...