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Reassessment Notice Beyond Ten Years Barred Under Section 149: Delhi High Court in KAD Housing Pvt. Ltd. v. DCIT (2024)
Facts of the
CaseThe petitioner, KAD Housing Private Limited,
challenged a notice dated 31.08.2024 issued under Section 148 of the
Income Tax Act, 1961, seeking to reopen the assessment for Assessment Year
(AY) 2015-...
Jurisdictional AO Cannot Issue Section 148 Notice After Faceless Reassessment Scheme, 2022: Delhi High Court in GDR Finance and Leasing Pvt. Ltd. v. ITO (2024)
Facts of the
CaseThe petitioner, GDR Finance and Leasing Private
Limited, was subjected to reassessment proceedings initiated by the Jurisdictional
Assessing Officer (JAO) through issuance of a notice under Section 14...
Reassessment under Section 148 Quashed Where Foreign Share Capital Accepted in Subsequent Years: Delhi High Court in Experion Hospitality Pvt. Ltd. v. ACIT (2024)
Facts of the
CaseThe petitioner, Experion Hospitality Pvt. Ltd.,
formerly known as Gold Resorts and Hotels Pvt. Ltd., is engaged in the
business of real estate and hospitality development. For Assessment Years 2008-09...
Reassessment under Section 148 Invalid When Subsequent Assessments Accept Share Capital: Delhi High Court in Experion Developers Pvt. Ltd. v. ACIT (2024)
Facts of the
CaseThe petitioners, belonging to the Experion Group
and engaged in real estate development, filed returns of income for Assessment
Years 2008-09 and 2011-12, which were either accepted under Section 143(...
Reassessment Notices Quashed Where Reasons Do Not Survive: Delhi High Court in Experion Developers Pvt. Ltd. v. Assistant Commissioner of Income Tax Reaffirms Limits of Section 148 Reopening
Facts of the
CaseThe batch of writ petitions was filed by Experion
Developers Pvt. Ltd. and Experion Hospitality Pvt. Ltd. challenging notices
issued under Section 148 of the Income Tax Act, 1961 for Assessment Years
...
Reassessment Proceedings Quashed for Non-Issuance of Notice under Section 143(2): Delhi High Court Upholds ITAT Order in CIT (International Taxation) v. Oracle Systems Corporation
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order dated 26.09.2022 passed by the Income Tax
Appellate Tribunal (ITAT) relating to Assessment Years 1997-98, 1998...
Mechanical Approval Under Section 151 Invalidates Reassessment Notice; Mere “Yes, I Am Satisfied” Not Enough – Capital Broadways Pvt. Ltd. vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Capital Broadways Pvt. Ltd., filed its
return of income for Assessment Year 2010-11 on 05.08.2010,
declaring an income of ₹1,95,711. The return was processed under Section
143(1) of ...
Mechanical Approval Under Section 151 Invalidates Reassessment Notice; Mere “Yes, I Am Satisfied” Not Enough – Capital Broadways Pvt. Ltd. vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Capital Broadways Pvt. Ltd., filed its
return of income for Assessment Year 2010-11 on 05.08.2010,
declaring an income of ₹1,95,711. The return was processed under Section
143(1) of ...
High Brand Value and Economic Scale Render BPO Giants Incomparable; TCS E-Serve and Infosys BPO Excluded from ALP Analysis – Cadence Design Systems (India) Pvt. Ltd. vs DCIT (Delhi High Court)
Facts of the CaseThe appellant, Cadence Design Systems (India) Private Limited,
challenged the order dated 05.01.2018 passed by the Income Tax Appellate
Tribunal for Assessment Year 2010-11, which had upheld the inclus...
Assessment Order Not Invalid Merely Due to Incorrect Heading or DIN Reference; Substance Prevails Over Form – BT Global Communications India Pvt. Ltd. vs DCIT (Delhi High Court)
Facts of the CaseThe petitioner, BT Global Communications India Pvt. Ltd.,
challenged an order dated 06.12.2019 passed by the Assessing Officer
assessing its total income at ₹5,47,92,27,510 for Assessment Year
2016-...