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CTCI Overseas Corporation Ltd. vs Director of Income Tax-I, International Taxation | Delhi High Court on Association of Persons (AOP) under Sections 2(31), 9(1)(i) & 90(2) of Income Tax Act
Facts of the Case
CTCI
Overseas Corporation Limited, a Hong Kong company, entered into a
consortium agreement with CINDA Engineering and Construction Private
Limited, India.
The
consortium wa...
Commissioner of Income Tax-IX vs High Tech Engineers | Reassessment under Sections 148, 143(2) & Deduction under Section 80HHC – DRI Allegations Cannot Sustain Addition Without Independent Evidence | Delhi High Court
Facts of the CaseThe assessee, High Tech Engineers, filed its original return
for Assessment Year 1998-99 declaring income of ₹4,04,930/-, which was
accepted. Subsequently, the Assessing Officer reopened the assessme...
Controls & Switchgear Contactors Ltd. vs Deputy Commissioner of Income Tax (DCIT) – Allowability of Director Guarantee Commission under Section 36(1)(ii) of the Income Tax Act, 1961 | Delhi High Court
Facts of the CaseThe petitioner company filed its income tax return for
Assessment Year 2006–07 and claimed deduction of guarantee commission amounting
to ₹48,75,000 paid to its Managing Director and another Direct...
Commissioner of Income Tax-VI vs Worldwide Township Projects Ltd.: Penalty under Sections 269SS, 271D and Limitation under Section 275(1)(c) of the Income Tax Act – Journal Entries and Book Transactions Not Treated as Loan Acceptance
Facts of the CaseThe assessee filed its income tax return for Assessment Year
2007–08. During scrutiny proceedings, the Assessing Officer observed that the
assessee had disclosed purchases of land amounting to approx...
Commissioner of Income Tax (C)-III vs M/s Flakes-N-Flavourz New Delhi & Anr – Section 80-IB Deduction Allowed by Settlement Commission | Scope of Judicial Review under Article 226 of Constitution of India
Facts of the CaseThe respondent/assessee filed an application for settlement
under Section 245C(1) of the Income Tax Act before the Income Tax Settlement
Commission. The respondent disclosed an additional income of app...
Commissioner of Income Tax-I vs M/s Cushman & Wakefield (India) Pvt. Ltd. – Delhi High Court on Transfer Pricing, Arm’s Length Price (ALP), Reimbursement of Expenses, Intra-Group Services and Section 92 of Income Tax Act
Facts of the CaseThe assessee, M/s Cushman & Wakefield (India) Pvt. Ltd.,
was engaged in rendering services relating to acquisition, sale and lease of
real estate properties, consultancy, advisory services, researc...
Commissioner of Income Tax-X vs. M/s Kultar Exports | Delay in Appeal Cannot Reopen Final Assessment Based on Subsequent Judgment | Section 80HHC & Section 260A Income Tax Act
Facts of the CaseThe assessee, M/s Kultar Exports, filed returns claiming
deductions under Section 80HHC of the Income Tax Act relating to profits
derived from export activities.Pursuant to the Taxation (Amendment) Act...
Commissioner of Income Tax-X vs M/s Kultar Exports (2014:DHC:2763-DB): Whether Assessee Can Reopen Final Assessment Based on Subsequent Judicial Decision under Section 80HHC
Facts of the CaseThe assessee, M/s Kultar Exports, filed income tax returns
claiming deductions under Section 80HHC of the Income Tax Act in respect of
export profits. Subsequently, through the Taxation (Amendmen...
Sanjay Gupta vs Commissioner of Income Tax (CIT) | Section 132A, Section 158B, Section 158BC, Section 158BE & Section 158BFA(2) of Income Tax Act – Determination of Block Period in Requisition Cases and Assessment of Undisclosed Income
Facts of the Case
The
assessee earned commission income from property transactions and trading
of transistor parts and also acted as an informer for the Directorate of
Revenue Intelligence (DRI).
O...
Sanjay Gupta vs Commissioner of Income Tax (CIT) | Determination of Block Period under Sections 132A, 158B, 158BC & Penalty under Section 158BFA(2) of the Income Tax Act, 1961 – Delhi High Court
Facts of the Case
The
assessee, Sanjay Gupta, derived income through commission in property
transactions and trading activities and also worked as an informer for the
Directorate of Revenue Intelligen...