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GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT’s Failure to Adjudicate Permanent Establishment (PE), Fees for Technical Services (FTS) & Attribution of Income | Delhi High Court
Facts of the
CaseThe appellant-assessee, GE Nuovo Pignone S.P.A.,
filed appeals under Section 260A challenging a common order passed by the
Income Tax Appellate Tribunal (ITAT) relating to Assessment Years 2001-02 to
...
Pr. Commissioner of Income Tax-Central-1 vs Sundeep Gupta & Sameer Gupta | Penalty under Section 271AAA cannot be imposed without admission during search statement | Delhi High Court
Facts of the
CaseA search assessment for Assessment Year 2010–11 was
completed under Section 153A of the Income Tax Act. Pursuant to additions made
during assessment, the Assessing Officer imposed penalty upon the a...
Pr. Commissioner of Income Tax-6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on Moratorium under Section 14 IBC and Continuation of Income Tax Appeals
Facts of the CaseThe Income Tax Department filed multiple appeals before the
Delhi High Court against the order of the Income Tax Appellate Tribunal
concerning the tax liability of Monnet Ispat & Energy Ltd. During...
Latika Datt Abbott & Anr. vs Director of Income Tax (Investigation Unit-II) & Ors. | Adjustment of Seized Cash Against Advance Tax Liability under Section 132B of the Income Tax Act
Facts of the CaseThe petitioners were subjected to a search and seizure
operation conducted by the Income Tax Department under the provisions of the
Income Tax Act, 1961. During the course of the search, substant...
MSD Pharmaceuticals Pvt. Ltd. Vs. Additional Commissioner of Income Tax & Anr. | Delhi High Court on Transfer Pricing Adjustment under Section 92CA – AMP Expenditure and Bright Line Test (AY 2011-12)
Facts of the
CaseThe present appeals were filed by the assessee, MSD
Pharmaceuticals Pvt. Ltd., pertaining to Assessment Year 2011–2012, involving
transfer pricing adjustments in relation to Advertisement, Marketing...
Pr. Commissioner of Income Tax-6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on Applicability of IBC Moratorium to Pending Income Tax Appeals under Sections 14, 238 & 7 of Insolvency and Bankruptcy Code, 2016
Facts of the CaseThe Income Tax Department filed multiple appeals before the
Delhi High Court challenging the order passed by the Income Tax Appellate
Tribunal (ITAT) concerning the tax liabilities of Monnet Ispat &...
GE Nuovo Pignone S.P.A. Vs Commissioner of Income Tax (International Taxation), Delhi – ITAT’s Failure to Adjudicate Grounds on Installation PE, Attribution of Income & Fees for Technical Services under Sections 254(2) and 260A of the Income Tax Act
Facts of the
CaseGE Nuovo Pignone S.P.A., the assessee, filed
multiple appeals challenging a common order passed by the ITAT for Assessment
Years 2001–02 to 2008–09.Before the ITAT, the assessee had specifically
...
Commissioner of Income Tax v. Vasavi Pratap Chand & Sidharth Pratap Chand | Delhi High Court | Capital Gains on Joint Development Agreement | Section 2(47), Section 48, Section 55 Income Tax Act & Section 7(4) Wealth Tax Act
Facts of the CaseThe dispute arose from the sale of developed flats constructed
on ancestral land situated at 6, Aurangzeb Road, New Delhi. The property
originally belonged to the family and was subsequently partitione...
Pr. Commissioner of Income Tax (Central)-3 & Anr. vs Ram Narain Jindal | Delhi High Court | Section 153A Income Tax Act | No Addition Without Incriminating Material During Search Proceedings
Facts of the CaseThe case involves the PR. Commissioner of Income Tax (Central)-3
challenging the Tribunal's ruling that set aside additions made under Section
153A of the Income Tax Act. The Tribunal applied the decis...
Pr. Commissioner of Income Tax–6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on Effect of IBC Moratorium on Pending Income Tax Appeals under Sections 14, 238 & 7 of Insolvency and Bankruptcy Code, 2016
Facts of the CaseThe Revenue Department had filed multiple income tax appeals
before the Delhi High Court challenging orders passed by the Income Tax
Appellate Tribunal in relation to the tax liabilities of Monnet Ispa...