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Director of Income Tax (International Taxation) vs M/s e-Funds IT Solution & e-Funds Corporation – Permanent Establishment under India–USA DTAA, Business Connection and Attribution of Income | Delhi High Court
Facts of the
Case
The assessees were companies incorporated in the United States and
were tax residents of the USA.
The foreign entities had international transactions with e-Funds
International India Pv...
Oswal Agro Mills Ltd. vs Commissioner of Income Tax (Delhi High Court) – Disputed Additional Customs Duty, Contingent Liability and Section 43B Deduction under Income Tax Act, 1961
Facts of the
CaseOswal Agro Mills Ltd. entered into agreements with
certain importers for the purchase of imported Palm Stearine Fatty Acid. Under
the agreements, the assessee agreed to purchase the imported material ...
Commissioner of Income Tax (Central)-II vs. Income Tax Settlement Commission & Anr. – Delhi High Court Clarifies That Immunity under Section 245H Cannot Be Granted Without Full and True Disclosure of Income
Facts of the
CaseA search operation under Section 132 of the Income
Tax Act was conducted on the business premises of the assessee and associated
group entities. During the search, incriminating materials, documents, ...
Ashwani Kumar Goel vs Income Tax Settlement Commission & Others – Scope of Settlement Commission Jurisdiction in Time-Barred Block Assessment Proceedings under Sections 245D, 245F and 158BE of the Income Tax Act
Facts of the
CaseSearch and seizure operations under the Income Tax
Act were conducted on 07.08.1997 at the residential and business premises of
the petitioner, his wife, and other relatives. Multiple documents and ma...
NTPC Ltd. Vs Commissioner of Income Tax-V | Delhi High Court on Section 263 Revision Powers, Provisional Reduction of Sales & Income Recognition under Income Tax Act
Facts of the CaseNTPC Ltd. filed its return of income for Assessment Year
2005–06 declaring total income of approximately Rs.1330.17 crores. The case was
selected for scrutiny and assessment proceedings were conducte...
Commissioner of Income Tax Vs. B.L. Passi – Depreciation on Trucks Given on Hire under Section 32 of the Income Tax Act: Ownership and Actual Business Use Upheld by Delhi High Court
Facts of the Case
The
assessee, B.L. Passi, operated a proprietary concern named M/s Pasco
Automobiles dealing in sale of Maruti cars on commission basis and also
earned income from partnership firms ...
Commissioner of Income Tax Vs. B.L. Passi – Depreciation on Trucks Given on Hire under Section 32 of the Income Tax Act: Ownership and Actual Business Use Upheld by Delhi High Court
Facts of the Case
The
assessee, B.L. Passi, operated a proprietary concern named M/s Pasco
Automobiles dealing in sale of Maruti cars on commission basis and also
earned income from partnership firms ...
Commissioner of Income Tax, New Delhi vs. M/s Manju Finance Corporation, New Delhi – Mandatory Satisfaction Note under Sections 158BD/158BC of the Income Tax Act for Block Assessment Proceedings
Facts of the
CaseSearch and seizure operations under Section 132(1)
of the Income Tax Act were conducted on 29.08.1996 at the residence of Shri Nem
Chand Gupta. During the search proceedings, books of account includin...
Pawan Kumar Aggarwal vs Income Tax Officer – Delhi High Court | Addition under Section 68 for Alleged Bogus NRI Gift to Minor Daughter | Genuineness of Gift Transaction and Burden of Proof
Facts of the Case
The assessee, Mr. Pawan Kumar Aggarwal, had a minor daughter, Aushi
Aggarwal, whose income was clubbed with his income under Section 64(1A) of
the Income Tax Act.
Aushi Aggarwal invested...
The Commissioner of Income Tax-II vs Jubilant Securities Pvt. Ltd.: Disallowance under Section 14A Read with Rule 8D and Allowability of Group Service Charges
Facts of the
CaseThe assessee had paid service charges amounting to
Rs.95,84,561/- to its group concern, M/s Jubilant Enpro Pvt. Ltd., under a
Memorandum of Understanding dated 05 January 2006. The said entity provide...