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Reassessment Notices Sustained Where JAO and FAO Have Concurrent Jurisdiction and Limitation Properly Extended under Section 149 Provisos – Surender Kumar Wadhwa vs. PCIT-18 (Delhi High Court)
Facts of the CaseThe petitioner, Surender Kumar Wadhwa, filed a
writ petition challenging the notice dated 26.03.2024 issued under Section
148A(b), the approval dated 09.04.2024 under Section 151, the order dated
09.0...
Reassessment Proceedings Set Aside for Non-Service of Notices on Correct Email Address: Violation of Natural Justice – Siam Stock Holdings Ltd. vs. DCIT (Delhi High Court)
Facts of the CaseThe petitioner, Siam Stock Holdings Limited, filed
a writ petition challenging the show cause notice dated 17.03.2023 issued under
Section 148A(b) of the Income-tax Act, 1961, the order dated 17.04.202...
Subsistence Allowance Exempt from Bank Attachment under Section 226(3): Revenue Directed to Permit Operation of Salary Account – Saumya Chaurasia vs. DCIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Saumya Chaurasia, approached the Delhi High Court challenging the
attachment of her bank account pursuant to an attachment notice dated
22.07.2024 issued under Section 226(3) of the I...
Compounding Charges at 5% Not Applicable Where Earlier Compounding Application Was Rejected: CBDT Guidelines Interpreted – Sangeet Seth vs. CCIT (Delhi High Court)
Facts of the CaseThe petitioner, Sangeet Seth, approached the Delhi
High Court seeking directions to the Chief Commissioner of Income Tax to pass a
compounding order under Section 279(2) of the Income-tax Act, 1961 in ...
Jurisdictional AO and Faceless AO Have Concurrent Power to Initiate Reassessment under Section 148: TKS Builders Reaffirmed Despite Dismissal of SLPs – Rhiti Talent Management Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Rhiti Talent Management Private
Limited, filed a writ petition as part of a batch of connected matters
challenging reassessment proceedings initiated under Section 148 of the
Income-ta...
Search of Multiple Bank Lockers under Section 132 Valid Where Bona Fide Reasons to Believe Exist; CBDT Instruction No. 1916 Not Absolute – Raj Krishan Gupta & Ors. vs. PDIT (Investigation) (Delhi High Court)
Facts of the CaseThe petitioners, members of the same family, filed
a writ petition seeking a declaration that the search and seizure conducted on
11.05.2024 under Section 132 of the Income-tax Act, 1961 on three bank ...
Reassessment Valid Where Risk Management Information Indicates Bogus Purchases and AO Applies Mind under Section 148A: No Interference in Writ Jurisdiction – R S Alloys vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, R S Alloys, a partnership firm
engaged in trading of ferrous and non-ferrous metals, filed its return of
income for Assessment Year 2019–20 under Section 139(1) of the Income-tax Act,...
Disallowance under Section 40(a)(i) Barred by Non-Discrimination Clause under DTAA; No TDS Obligation Where Income Not Chargeable to Tax: Revenue Appeal Dismissed – PCIT-04 vs. Mitsubishi Corporation (India) Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 12.08.2022 passed by the
Income Tax Appellate Tribunal in ITA No. 9364/Del/2019 for Assessment Yea...
Interest on FDRs Earned from Project-Linked Funds Is Capital Receipt and Not Income from Other Sources: Revenue Appeal Dismissed – PCIT-1 vs. Brahma Center Development Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 17.07.2023 passed by the
Income Tax Appellate Tribunal, Delhi Bench, allowing the appeal of the
a...
AMP Expenses Not an International Transaction; Bright Line Test Impermissible; Revenue Appeals Dismissed – PCIT-1 vs. Casio India Co. Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of
the Income-tax Act, 1961 challenging the common order dated 24.02.2020 passed
by the Income Tax Appellate Tribunal, Delhi Bench, deciding ITA Nos.
385/D...