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ITAT Delhi: No Double Addition When Amount Already Offered as Sales – Receivable from Holding Company Cannot Be Taxed Again | Paschimanchal Vidyut Vitran Nigam Ltd. vs DCIT
Facts of the
CaseThe assessee, Paschimanchal Vidyut Vitran Nigam Ltd., is engaged in the
distribution of electricity and is a 100%
subsidiary of UPPCL (Uttar Pradesh Power Corporation Limited). The
company operates a...
Discovery Networks Asia Pacific Pte Ltd vs ACIT – ITAT Delhi: Taxability of Advertisement & Distribution Revenue of Foreign Broadcaster, PE Profit Attribution and Royalty Issue under Section 9(1)(vi) & India-Singapore DTAA
Facts of the CaseDiscovery Networks Asia Pacific Pte Ltd (DNAP), a
tax resident company of Singapore, is engaged in the business of broadcasting
television channels such as Discovery Channel, Animal Planet, TLC, Discov...
ACIT vs Zoom Communication Ltd (ITAT Delhi): Addition on Unreceived Contract Revenue Deleted – Only Real Income Taxable u/s 5(1)(b); Employee Remuneration & Professional Fees Allowable
Facts of the CaseThe assessee, Zoom Communication Ltd, is engaged in providing video production
services. During the relevant assessment year, it undertook a contract with SIS Live (UK) for production and
coverage faci...
ITAT Delhi: BITO-Lagertechnik Bittmann GmbH vs ACIT – Addition Cannot Be Made Without Proper Basis or Evidence
Facts of the CaseThe assessee, BITO-Lagertechnik Bittmann GmbH, is a foreign
company engaged in business activities relating to storage technology and
logistics solutions. During the relevant assessment year, the asses...
ITAT Delhi: Capital Gains on Sale of Indian Shares by Mauritius Entity Taxable Only in Mauritius under India–Mauritius DTAA – DCIT v. Battery Ventures VII (AY 2017-18)
Facts of the CaseThe assessee, Battery Ventures VII (Mauritius), is a limited
liability company incorporated in Mauritius. During the assessment proceedings,
the assessee furnished Tax Residency Certificates issued by ...
No Addition u/s 153A Without Incriminating Material Found During Search – DCIT vs iServices Investments Ltd (ITAT Delhi)
Facts of the CaseA search and seizure operation under Section 132 of the Income
Tax Act, 1961 was conducted by the Investigation Wing on 22.03.2012.Pursuant to the search, the Assessing Officer issued notice
under Sect...
AAPC Singapore Pte. Ltd. v. ACIT (ITAT Delhi): Reservation, Marketing & Loyalty Programme Receipts Not Taxable as Royalty under Section 9(1)(vi) and India–Singapore DTAA
Facts of the CaseThe assessee, AAPC Singapore Pte. Ltd., a company incorporated
in Singapore, entered into franchise agreements with Indian entities to
sub-license hotel brand names to third-party hotels operating in I...
ITAT Delhi: Profit Cannot Be Estimated at 25% on Bank Cash Deposits Without Examining Past Profit History – Parmod Kumar vs ITO (ITA No. 3104/Del/2023)
Facts of the CaseThe assessee, Mr. Parmod Kumar, filed his return of income
declaring profit from his business activities. For the Assessment Year 2011-12,
the assessment proceedings were initiated pursuant to notice i...
Assessment Order Without DIN is Invalid and Deemed Never Issued – ITAT Delhi in Ajay Kumar vs DCIT (A.Y. 2016-17 to 2018-19)
Facts of the CaseThe assessee filed appeals against the orders of the
Commissioner of Income Tax (Appeals), Kanpur-4 arising from assessment orders
passed by the Assessing Officer under section 143(3) read with section...
Non-Compliance of E-Notice Due to Employee Leaving Company Constitutes Reasonable Cause – ITAT Delhi in Egis International S.A.S vs ACIT (ITA No. 2333/Del/2022)
Facts of the CaseEgis International S.A.S., a foreign company engaged in
providing technical consultancy services to associated enterprises and third
parties, filed its income tax return for the relevant assessment yea...