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Immunity Under Section 245H Cannot Be Granted Without Recording Satisfaction of Full and True Disclosure; Review Petitions Dismissed – CIT (Central)-II vs. Standard Farms Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue had filed writ petitions challenging the order
dated 27.06.2013 passed by the Income Tax Settlement Commission granting
immunity from penalty and prosecution to the respondents, Standard Fa...
Section 263 Cannot Be Invoked on Mere Allegations of Tax Avoidance Without Demonstrating Error or Prejudice; Share Transfer Exempt Under Section 47(iv) Upheld – CIT (IT)-2 vs. Genpact Consulting Singapore Pte. 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 13.06.2022 passed by the
Income Tax Appellate Tribunal, whereby the Tribunal had quashed the revis...
Reassessment for AY 2014–15 Barred by Limitation Where No Asset Found in Search; Section 153C Timelines Mandatory Post Finance Act 2021 – ATS Township Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the CaseThe petitioner, ATS Township Pvt. Ltd., filed a writ petition
challenging the notice dated 23.08.2024 issued under Section 148A(b) of the
Income-tax Act, 1961, the order dated 31.08.2024 passed under S...
No Further Profit Attribution to Indian PE Once ALP Accepted; Issues Squarely Covered by Morgan Stanley – CIT (International Taxation)-1 vs. Adobe Systems Software Ireland Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 09.02.2024 passed by the
Income Tax Appellate Tribunal in the case of Adobe Systems Software Irel...
Reassessment Order Invalid for Violation of Natural Justice Where New Allegations Not Put to Assessee; AO Becomes Functus Officio After Completed Assessment: Vivo Mobile India Pvt. Ltd. vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Vivo Mobile India Private Limited,
filed a writ petition challenging the show cause notice dated 09.08.2024 issued
under Section 148A(b) of the Income-tax Act, 1961 for Assessment Year...
Offshore Supply of Telecom Equipment and Software Not Taxable in Absence of Permanent Establishment; Subsidiary Does Not Constitute Fixed Place or Dependent Agent PE Without Contract-Concluding Authority: CIT (International Taxation)-2 vs. Nokia Corporation (Delhi HC)
Facts of the
CaseThe batch of appeals was filed by the Revenue
against orders of the Income Tax Appellate Tribunal relating to multiple
assessment years concerning Nokia Network OY, later known as Nokia Corporation,
...
No Further Profit Attribution to Indian PE Once ALP Accepted; Issues Squarely Covered by Morgan Stanley – CIT (International Taxation)-1 vs. Adobe Systems Software Ireland Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 09.02.2024 passed by the
Income Tax Appellate Tribunal in the case of Adobe Systems Software Irel...
Nil Withholding Certificate Cannot Be Denied on Mere Suspicion of PE; Section 197 Requires Prima Facie Taxability Analysis Following Rule 28AA – SFDC Ireland Ltd. vs. CIT (Delhi HC)
Facts of the
CaseThe petitioner, SFDC Ireland Limited, is a tax
resident of the Republic of Ireland and is engaged in the business of providing
standardized customer relationship management software products. It enter...
Bad Debt Write-off on One-Time Group Guarantee Not Allowable Where Guarantee Not Given in Ordinary Course of Business; ITAT Order Set Aside – PCIT-7 vs. WGF Financial Services Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe assessee, WGF Financial Services Pvt. Ltd.,
filed its return for Assessment Year 2015-16 declaring a loss, which was later
revised. The assessment under Section 143(3) resulted in additions includ...
Section 153C Proceedings Invalid in Absence of Incriminating Material Pertaining to Relevant AYs; Provisional Balance Sheet of Later Period Insufficient – PCIT (Central)-3 vs. Ridgeview Construction 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 31.10.2018 passed by
the Income Tax Appellate Tribunal, whereby proceedings initiated under ...