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Ericsson India Private Limited vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1), 143(2), 241A & 143(1D) of Income Tax Act
Facts of the
CaseThe Petitioner, Ericsson India Private Limited,
engaged in telecommunication equipment business, filed income tax returns for
multiple Assessment Years (AY 2016–17, 2017–18, 2018–19), claiming s...
Ericsson India Private Limited vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1D) & 241A of Income Tax Act
Facts of the
Case
The petitioner, Ericsson India Pvt. Ltd., engaged in telecom
equipment business, filed returns for AY 2016-17, 2017-18, and 2018-19
claiming substantial refunds due to excess TDS deductio...
Ericsson India Pvt. Ltd. vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1), 143(2), 143(1D) & 241A of Income Tax Act
Facts of the
CaseThe Petitioner, Ericsson India Pvt. Ltd.,
engaged in telecom equipment manufacturing and services, filed returns for AY
2016-17, 2017-18, and 2018-19 claiming substantial refunds due to excess TDS
de...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (Delhi High Court, 2020) – Attribution of Profits to Permanent Establishment Restricted to 35%
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order passed by the Income Tax Appellate
Tribunal (ITAT) concerning Assessment Years 2004-05, 2006-07, 2007-08, and
...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (2020) – Delhi High Court | Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
Case
The appeals were filed by the Commissioner of Income Tax
(International Taxation)-3 against a common order of the ITAT dated
28.05.2019.
The dispute covered Assessment Years: 2004-05, ...
Commissioner of Income Tax – International Taxation–3 vs Rolls Royce PLC (Delhi High Court) – Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 28.05.2019 passed by the ITAT, New Delhi Bench,
concerning Assessment Years 2004-05, 2006-07, 2007-08, and 2009-10. The dispu...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (2020) – Delhi High Court | Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
Case
The appeals were filed by the Commissioner of Income Tax
(International Taxation)-3 against a common order of the ITAT dated
28.05.2019.
The dispute covered Assessment Years: 2004-05, ...
Rajesh Khetarpal & Ors. vs Assistant Commissioner of Income Tax & Ors. | Delhi High Court | Reassessment Notices under Section 148 & Applicability of Amended Provisions Post Finance Act 2021
Facts of the
Case
Multiple writ petitions were filed challenging reassessment notices
issued after 1 April 2021 under the old provisions of Section 148.
The Finance Act, 2021 introduced a new reassessment reg...
Commissioner of Income Tax vs. M/s Prasidh Leasing Ltd. | Delhi High Court | Deemed Dividend under Section 2(22)(e) of Income Tax Act, 1961 | Trade Advance vs Loan Classification
Facts of the CaseThe assessee, M/s Prasidh Leasing Ltd., had shown M/s Ginza
Industries Ltd. as a sundry creditor in its books, with substantial funds
advanced by Ginza for the alleged procurement of import licenses. T...
Meera Gupta vs Deputy Commissioner of Income Tax & Ors. | Delhi High Court on Maintainability of Writ Petition Against Section 153A Assessment Order When Statutory Appeal is Already Filed
Facts of the CaseThe petitioner challenged assessment orders passed under Section
153A of the Income Tax Act, 1961 before the High Court through writ
petitions. Simultaneously, it was admitted before the Court that the...