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Indian Subsidiary Not a Permanent Establishment: Delhi High Court Quashes Reassessment Notices in Progress Rail Locomotive Inc. v. DCIT (International Taxation) (2024)
Facts of the CaseThe writ petitions challenged reassessment notices issued
under Section 148 of the Income Tax Act, 1961 for Assessment Years 2012–13 to
2018–19 to Progress Rail Locomotive Inc. (formerly Electro Mo...
ITO (Exemption) Allahabad vs Hindi Sahitya Sammelan, Allahabad — ITAT Allahabad on Accumulation of Income Without Form 10, Compliance under
Facts of the
CaseThe assessee, a registered
educational and charitable society, reported substantial gross receipts during
the relevant assessment year. After incurring revenue expenditure and capital
spending, the s...
Interest on Refund of Cancelled Auction Deposit Is Capital Receipt, Not Taxable: Delhi High Court in PCIT-4 v. INS Finance & Investment Pvt. Ltd. (2024)
Facts of the CaseThe central issue before the Delhi High Court was whether
interest received by the assessee on the principal amount deposited in an
auction—which was subsequently annulled—constituted a capital rec...
Sanjiv vs. ACIT (ITAT): Tribunal Decision on Assessment Additions and Appellate Relief — Findings under Relevant Provisions of the Income-tax Act
Facts of the CaseThe assessee, Sanjiv, was subjected to assessment
proceedings in which the Assessing Officer made certain additions to the
declared income. The assessee challenged these additions before the
Commissio...
Insurance Claim Provisions & IBNR Are Ascertained Liabilities: Delhi High Court Upholds Deduction in PCIT-1 v. Care Health Insurance Ltd. (2024)
Facts of the CaseThe Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT) which had deleted disallowances made by the Assessing Officer
in respect of provisions for unsettled claims and “Incurred ...
Section 68 Additions in Search Case Invalid Without Incriminating Material & Cross-Examination: Delhi High Court in PCIT (Central)-3 v. Pavitra Realcon Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed appeals challenging the order dated 04
October 2017 passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Year 2011–12 concerning M/s Pavitra Realcon Pvt. Ltd., along wi...
Search Assessment Invalid Without Incriminating Material & Cross-Examination: Delhi High Court Dismisses Revenue Appeal in PCIT (Central)-3 v. Design Infracon Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed appeals challenging the order dated 04
October 2017 passed by the Income Tax Appellate Tribunal (ITAT) concerning
Assessment Year 2011-12 in respect of M/s Design Infracon Pvt. Ltd., ...
No Addition Under Section 68 Without Incriminating Material: Delhi High Court Dismisses Revenue Appeal in PCIT (Central)-3 v. Delicate Realtors Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed appeals challenging the order dated 04
October 2017 passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Year 2011–12 concerning M/s Pavitra Realcon Pvt. Ltd., M/s Deli...
Search Additions Cannot Be Based on Presumptions: Delhi High Court Upholds ITAT Deleting Section 68 & 69 Additions in PCIT (Central)-3 v. GTM Builders & Promoters Pvt. Ltd. (2024)
Facts of the
CaseThe Revenue filed
multiple appeals against orders of the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2006-07 and 2007-08 relating to M/s GTM Builders
& Promoters Pvt. Ltd. an...
Reassessment After 4 Years Invalid Without Fresh Tangible Material: Delhi High Court Dismisses Revenue Appeal in PCIT Delhi-8 v. Samsung India Electronics Pvt. Ltd. (2024)
Facts of the CaseThe Revenue appealed against the order of the Income Tax
Appellate Tribunal (ITAT) dated 23 February 2018, which invalidated
reassessment proceedings for Assessment Year 2002-03 on the ground that they...