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PR. Commissioner of Income Tax-7 vs Royal and Sun Alliances IT Solutions (India) Pvt. Ltd. (2019) – Penalty u/s 271(1)(c) on Transfer Pricing Adjustment Held Unsustainable (Delhi High Court)
Facts of the
CaseThe Revenue filed an appeal under Section 260A
of the Income Tax Act, 1961 challenging the order of the Income Tax
Appellate Tribunal (ITAT), which had set aside the penalty imposed under Sectio...
M/s JBM Industries Ltd. vs Commissioner of Income Tax, New Delhi (Delhi High Court) – Disallowance of Foreign Education Expenses under Section 37(1) of the Income Tax Act
Facts of the Case
The
assessee company incurred expenses towards foreign education (MBA at
Boston University, USA) of Ms. Esha Arya, daughter of one of its Directors.
The
expenditure claimed ...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court, 2020) – ITAT Remand to DRP Set Aside on Permanent Establishment Issue under Sections 147/148
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged
the order of the Income Tax Appellate Tribunal (ITAT), which had remanded
multiple appeals back to the Dispute Resolution Panel (DRP). The remand w...
Pr. Commissioner of Income Tax-3 vs Dr. Oetker India Pvt. Ltd. (Delhi High Court) – Section 145 Income Tax Act | Rejection of Books & Gross Profit Addition
Facts of the
Case
The assessee, Dr. Oetker India Pvt. Ltd., is engaged in
manufacturing and sale of processed food products.
The return of income was filed declaring income of ₹3,57,13,770 for
A...
The Pr. Commissioner of Income Tax-3 vs Dr. Oetker India Pvt. Ltd. – Section 145 Income Tax Act | Inventory Valuation & Net Profit Addition Case | Delhi High Court
Facts of the
Case
The assessee is engaged in manufacturing and sale of processed food
products.
It filed its return declaring income of Rs. 3,57,13,770 for AY
2010–11.
The case was selected f...
M/s JBM Industries Ltd. vs Commissioner of Income Tax, New Delhi (2019) – Disallowance of Educational Expenses under Section 37(1) of the Income Tax Act
Facts of the CaseThe appellant, M/s JBM Industries Ltd., filed multiple
appeals against a composite order passed by the Income Tax Appellate Tribunal
concerning Assessment Years 2001–02 to 2004–05. The primary issu...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Cannot Remand When Facts Are Already on Record | Section 147/148 Income Tax Act
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order passed by the Income Tax Appellate Tribunal (ITAT), wherein the Tribunal
remanded the matter back to the Dispute Resolution Panel (DRP) f...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Cannot Remand When Facts Are Already on Record | Sections 147/148 & Permanent Establishment
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order of the Income Tax Appellate Tribunal (ITAT), which had remanded the
matter back to the Dispute Resolution Panel (DRP). The core issue rev...
Commissioner of Income Tax (Exemption) vs Indo-French Centre for Promotion of Advanced Research (Delhi High Court) – No Addition on Foreign Government Grants, FCRA Not Applicable
Facts of the CaseThe present appeal was filed by the Revenue against the order
of the Income Tax Appellate Tribunal concerning Assessment Year 2010–11. The
Tribunal had upheld the order of the Commissioner of Income ...
PR. Commissioner of Income Tax-4, Delhi vs Itochu India Pvt. Ltd. (2019) – Transfer Pricing | ALP Determination under TNMM | Section 92C & Rule 10B Analysis
Facts of the
CaseThe present appeals were filed by the Revenue
against separate orders of the Income Tax Appellate Tribunal (ITAT) for
Assessment Years 2007-08, 2008-09, and 2009-10. The assessee, Itochu India P...