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Pioneer Overseas Corporation v/s Additional Director of Income Tax: Parallel Appeals Withdrawn under Section 260A Post-Conclusive Dispute Settlement under Section 90 under India-USA Double Taxation Avoidance Agreement Mutual Agreement Procedure
Facts of the CaseThe appellant, Pioneer Overseas Corporation, had filed a
series of Income Tax Appeals (ITA Nos. 1210/2010, 1211/2010, 1212/2010,
1213/2010, and 1223/2010) before the Hon’ble High Court of Delhi. Subs...
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...
Commissioner of Income Tax Delhi-IV vs Delhi Tourism & Transportation Development Corporation Ltd – Deduction under Section 80M of Income Tax Act on Dividend Distribution Not Restricted to Same Assessment Year | Delhi High Court
Facts of the CaseThe respondent assessee, Delhi Tourism & Transportation
Development Corporation Ltd., a domestic company wholly owned by the Government
of NCT of Delhi, filed its return for Assessment Year 1993–...
Replika Press Pvt. Ltd. & Anr. Vs. Assistant Commissioner of Income Tax: Reopening U/s 147 Based on Audit Party’s Interpretation of Section 10B Is an Impermissible Change of Opinion
Facts of the Case
The
petitioner, Replika Press Private Limited, operates a 100% export-oriented
unit (EOU) engaged in manufacturing and exporting printed books.
The
petitioner filed its return of ...
Commissioner of Income Tax vs. Abhinav Kumar Mittal: Valid Material Found During Search is a Condition Precedent for DVO Reference Under Section 69 of the Income Tax Act
Facts of the Case
Assessee
Return: The respondent/assessee filed his original
return of income for the Assessment Year 2006-07 on July 18, 2006,
declaring a total income of ₹39,90,410/-.
Search
...
Ranbaxy Laboratories Ltd. Vs. Deputy Commissioner of Income Tax: Validity of Reopening Assessment Under Section 147/148 Beyond Four Years Based on Audit Memos and Alleged Change of Opinion
Facts of the Case
The
petitioner, Ranbaxy Laboratories Ltd., challenged a notice dated
29.03.2010 issued under Section 148 of the Income Tax Act, 1961.
The
notice proposed to re-open the assessment...
Commissioner of Income Tax vs. Bharti Airtel Limited: Delhi High Court Ruling on Limitation Period for Revision under Section 263(2)
Facts
of the Case·
Assessment Year: The appeal by the Revenue pertained to the
Assessment Year 2005-06. ·
Original
As...
Shivalik Bimetal Controls Ltd. vs. Income Tax Officer : Validity of Reopening Notice under Section 148 Beyond 4 Years Without Failure to Disclose Material Facts
Facts of the Case
For
the Assessment Year (AY) 2005-06, the initial assessment of the
petitioner, Shivalik Bimetal Controls Ltd., was completed under Section
143(3) of the Income Tax Act, 1961, on Apr...
M/s Lord Chloro Alkalies Ltd. vs Director General of Income Tax (Admn.) & Anr. – Delhi High Court | Validity of BIFR Rehabilitation Scheme for Waiver of Interest under Income Tax Act vis-à-vis SICA, Sections 32, 22 and Section 119 of Income Tax Act
Facts of the CaseM/s Lord Chloro Alkalies Ltd., originally incorporated as Modi
Alkalies & Chemicals Ltd., commenced production of caustic soda and
initially operated satisfactorily. Subsequently, owing to adverse ...
Dalmia Cement (Bharat) Ltd. Vs. Commissioner of Income Tax | Applicability of Section 43B on Cess and Surcharge
Facts of the Case:·
The assessee claimed an expenditure
of Rs. 1,45,29,207 for the assessment year (AY) 1985-86 as an accrued liability
to pay cess and cess surcharge u...