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Puneet Kulthia vs ITO – ITAT Delhi | Reassessment u/s 147 Held Invalid Where Case Falls Under Section 153C – Addition u/s 68 Deleted
Facts of the CaseThe assessee, Shri Puneet Kulthia, filed his return of income
for the relevant assessment year declaring his income. The case was later
reopened by the Assessing Officer by issuing notice under Section...
Ajay Kumar Sharma vs ITO – ITAT Delhi Remands Share Valuation Dispute on FMV Determination under Rule 11UA for Capital Gains Computation (AY 2016-17)
Facts of the CaseThe assessee filed his return of income electronically on
28.02.2017 declaring total income of ₹12,68,070. The case was selected for
scrutiny assessment and statutory notices were issued. During asse...
ITAT Delhi: Exemption u/s 10(23C)(vi) for Educational Society – Assessment Set Aside Pending Decision on Exemption Application | S.D. Education Society vs ITO
Facts of the CaseThe assessee, S.D. Education Society, is an educational
society engaged in running educational institutions and claiming exemption
under Section 10(23C)(vi) of the Income Tax Act, 1961.For Assessment Y...
ITAT Delhi: Addition under Section 56(2)(viib) Cannot Be Made When Shares Are Valued Using DCF Method Supported by Valuation Report – ITO vs Kaka Services Pvt. Ltd.
Facts of the CaseThe assessee company, Kaka Services (P) Ltd., was engaged in
the business of financial services and was registered with the Reserve Bank of
India as a Non-Banking Financial Company (NBFC).The assessee ...
ACIT vs Verizon India Pvt. Ltd. – Penalty u/s 271(1)(c) Not Leviable Where Transfer Pricing Adjustment Arises from Bona Fide Difference in Comparables and Full Disclosure Made (ITAT Delhi)
Facts of the CaseThe assessee, Verizon India Pvt. Ltd., filed its return of
income along with a Transfer Pricing study report for its international
transactions with associated enterprises. The assessee adopted the
Tr...
Child Compassion Care India vs CIT(E) – ITAT Delhi Dismisses Appeal as Withdrawn | AY 2018-19 | Income Tax Appellate Tribunal Case Law
Facts of the CaseThe assessee, Child Compassion Care India, is a charitable
organization registered under the provisions of the Income-tax Act and engaged
in charitable activities. The organization claimed exemption un...
Ameriprise India Pvt. Ltd. vs ACIT – ITAT Delhi on Transfer Pricing Adjustment, Selection of Comparables and Treatment of Foreign Exchange Gain/Loss under Sections 92C & 92CA
Facts of the
CaseThe assessee,
Ameriprise India Pvt. Ltd., is a wholly owned subsidiary of Ameriprise USA,
engaged in providing Information Technology Enabled Services (ITES) and
back-office support services to its A...
DCIT vs Suruchi Foods Pvt. Ltd. – ITAT Delhi on Taxability of Keyman Insurance Policy Proceeds and Applicability of Section 10(10D) of the Income Tax Act
Facts of the
CaseThe dispute in the
present case arose in relation to the taxability of proceeds received from a
Keyman Insurance Policy originally taken by Suruchi Foods Pvt. Ltd. in the name
of its director.The com...
ITAT Delhi: CPC Cannot Make Adjustment Without Prior Intimation Under Section 143(1)(a) – Brahma Investments I Ltd. vs DCIT
Facts of the
CaseThe assessee, Brahma
Investments I Ltd., a tax resident of Cyprus, filed its return of income on 15.02.2021
declaring total income of ₹1,13,33,890. In the return, the assessee reported a long-term
...
Lex Sportel Vision Pvt. Ltd. vs ITO (ITAT Delhi) – Payment for Live Telecast Rights Not Taxable as Royalty u/s 9(1)(vi); No TDS Liability u/s 195 on “Live Rights”
Facts of the
CaseThe assessee, Lex
Sportel Vision Pvt. Ltd., is engaged in the business of acquiring and
sub-licensing broadcasting rights of various sports events such as cricket,
golf and football. For the Assessme...