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Delhi High Court in M/s Xerox Modicorp Ltd. vs. DCIT: Reassessment Notices u/s 147/148 Quashed; Recorded Reasons Cannot Be Supplemented for Post-4-Year Reopenings, and Audit Opinions Do Not Constitute Tangible Material Within 4 Years
Facts of the Case
The
Petitioner’s Profile: The petitioner is a company engaged in
the export of software, the manufacture of photocopiers, and trading in
fax machines, paper, and toner.
The
...
Rollatainers Limited vs Deputy Commissioner of Income Tax – Reassessment under Section 148/147 of Income Tax Act, 1961
Facts of the
Case
Petitioner, Rollatainers Limited, is engaged in the
manufacturing of packing materials.
Filed its return for AY 2003-04 declaring a loss of ₹2.48 crores.
Original assessment complet...
Commissioner of Income Tax vs. Samsung India Electronics Ltd. | Deductibility of Interregnum Expenses Under Section 37 of Income Tax Act
Facts of the CaseThe respondent-assessee, Samsung India Electronics
Ltd., is a joint venture company incorporated on August 3, 1995. The company
received its certificate of commencement of business on August 29, 1995.
...
DIRECTOR OF INCOME TAX vs. McDONALDS CORPORATION: Validity of Reassessment Proceedings Under Section 147/148 Based on a Mere Change of Opinion Where Primary Facts Were Fully Disclosed
Facts of the Case
The
Arrangement: The assessee, McDonalds Corporation (USA),
entered into a Master Licensing Agreement (MLA) on January 1, 1996, with
McDonalds India Private Limited (MIPL). Under thi...
Commissioner of Income Tax vs Samsung India Electronics Ltd. – Defective Stock Valuation under Section 115JA and Allowability of Employee Training Expenses | Delhi High Court
Facts
of the Case
The assessee, Samsung India
Electronics Ltd., had written off defective stock amounting to
Rs.1,20,07,908/- by valuing it at realizable market value, which was lower
than the cost p...
The Commissioner of Income Tax Vs. M/s Intercontinental Trading & Investment Co. Ltd. (On the Mandatory Requirement of Recording Satisfaction for Assuming Jurisdiction Under Section 158BD of the Income Tax Act, 1961)
Facts of the Case
Search
and Seizure: A search operation under Section 132 of the
Income Tax Act, 1961, was conducted on November 22, 1996, at the premises
of M/s Hindustan Development Corporation Lim...
JD Tytler School Society vs. Director General of Income Tax (Exemption) & Anr. — Remand of Exemption Claims Under Section 10(23C)(vi) Following Post-Order Amendment of Memorandum of Association
Facts of the Case
Parties
Involved: The petitioner is the JD Tytler School
Society , and the respondents are the Director General of Income Tax
(Exemption) and others.
Impugned
Orders: The pe...
Delhi High Court in CIT vs. Avinash Jain: Revenue Cannot Recharacterize Capital Gains into Business Income Where Assessee Maintains Distinct Dual Share Portfolios Consistent with Historical Practice and CBDT Circular No. 4/2007
Facts of the Case
The
Assessee (Avinash Jain) was engaged in the sale and purchase of shares.
The
Assessee consistently maintained two distinct separate portfolios: an investment
portfolio (compris...
Delhi High Court in CIT vs. Nahar Theaters: De Novo Remand under Section 254 due to ITAT’s Failure to Verify Record Status of Critical 2002 MOU, While Sustaining the Finality of Annual Letting Value under Sections 22 and 23
Facts of the Case
This
case involves three interconnected appeals filed by the Revenue, namely
ITA 845/2009, ITA 909/2009, and ITA 1409/2010.
The
underlying appeals pertain to the Assessment Years ...
Commissioner of Income Tax, Delhi-IV vs DLF Commercial Developers Ltd. | Delhi High Court on Derivative Trading Loss, Speculative Loss and Applicability of Explanation to Section 73 of Income Tax Act, 1961
Facts of the CaseThe assessee, DLF Commercial Developers Ltd., claimed a loss
of approximately ₹492.71 lakhs arising from purchase and sale transactions
involving derivatives. The assessee contended that such derivat...