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Commissioner of Income Tax (Ghaziabad) vs. Krishna Gupta & Ors. – Scope of Power of Total Recall and Rectification under Section 254(2) of the Income Tax Act, 1961
FACTS OF THE CASE
Original
Assessment & ITAT Order: For the Assessment Year
1992-93, a best judgment assessment was executed against the assessee. The
Assessing Officer (AO) computed the gross pro...
Rose Serviced Apartments Pvt. Ltd. & Anr. vs. Deputy Commissioner of Income Tax: Validity of Reassessment Under Section 147/148 Based on Mere Change of Opinion and Audit Objection
Facts of the Case
The
Assessee's Return: Petitioner No. 1 (Rose Serviced
Apartments India Pvt. Ltd.), a company engaged in trading long-term
investments and real estate, filed its return of income for...
Commissioner of Income Tax vs. Agra Beverages Corporation P. Ltd.Franchisee Business Expenditures and Commercial Expediency under Section 37(1)
Facts of the Case
The
respondent-assessee was a franchisee of M/s. Pepsi Food (Pvt.) Ltd.
(Pepsi). Under this Franchisee Agreement, the assessee held exclusive
rights for bottling, selling, and distri...
Smt. Kalawanti Garg vs. Commissioner of Income Tax Cash Gifts from Minor Sons and Unverifiable Cash Loans Added as Unexplained Cash Credits Under Section 68
Facts of the Case
Assessee
Background: The appellant/assessee is an individual
engaged in the business of civil contract. For the Assessment Year (AY)
2006-07, she filed her income tax return declarin...
The Commissioner of Income Tax v. M/s. Agra Beverages Corporation P. Ltd. (Allowability of Business Expenditure under Section 37(1) on Visi-Cooler Hire Charges and Advertisement Expenses Incurred by Franchisee Benefiting the Trademark Owner)
Facts of the Case
Franchisee
Agreement: The respondent-assessee entered into a
franchisee agreement with M/s. Pepsi Food (Pvt.) Ltd. ("Pepsi")
for manufacturing, bottling, selling, and distributing Pe...
CIT vs. Gillette Diversified Operations Pvt. Ltd. | Sale of Shares to Group Company Before Amalgamation to Mitigate Liability is Not a Colourable Device for Tax Avoidance Under Section 45 & 48
Facts of the Case
The
respondent/assessee, Gillette Diversified Operations Pvt. Ltd. (GDOPL),
was engaged in the business of leasing equipment and filed a return
declaring a loss of ₹4,71,54,2...
Commissioner of Income Tax vs. Intex Technology India Ltd. & Commissioner of Income Tax vs. Narender Bansal | Block Assessment Under Section 158BC and Share Application Money Cash Credits Under Section 68 Disallowed Upon Genuineness Verification
Facts of the CaseThe Revenue preferred two connected appeals before
the High Court of Delhi challenging a common order passed by the Income Tax
Appellate Tribunal (ITAT) concerning the block assessment period fro...
Commissioner of Income Tax vs. M/s. [Assessee Name] | Deductions Under Section 36(1)(ii) for Commission and Bonus Paid to Managing Director Allowed
Facts of the Case
The
case involves two income tax appeals (ITA Nos. 73/2010 & 1717/2010)
pertaining to the assessment years 2004–2005 and 2005–2006.
In
its returns, the respondent-assessee...
Commissioner of Income Tax, IV vs. M/s. Hindustan Coca Cola Marketing Co. Pvt. Ltd. (and M/s. Hindustan Coca Cola Beverages Pvt. Ltd.) – Section 263 Revisional Powers Cannot Be Invoked Merely Due to a Difference of Opinion
Facts of the CaseThe Assessing Officer (AO) passed assessment orders for two
assessment years concerning the assessees (M/s. Hindustan Coca Cola Marketing
Co. Pvt. Ltd. and M/s. Hindustan Coca Cola Beverages Pvt. Ltd.)...
Commissioner of Income Tax vs. M/s. Hindustan Coca Cola Marketing Co. Pvt. Ltd. & Ors.: Scope of Revisionary Power under Section 263 of Income Tax Act, 1961
Facts of the CaseThe dispute arose from assessment orders passed by the
Assessing Officer (AO) regarding two separate assessment years for the sister
concerns, M/s. Hindustan Coca Cola Marketing Co. Pvt. Ltd. and M/s. ...