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Director of Income Tax vs. M/s Mitsubishi & Connected Assessees – No Interest under Section 234B Where Income is Subject to TDS | Delhi High Court
Facts of the
CaseThe Revenue Department filed multiple appeals
before the Delhi High Court challenging the relief granted to the assessees on
the issue of charging interest under Section 234B of the Income-tax Act, 19...
Commissioner of Income Tax vs. M/s Kishore Apparels [2010] 2010:DHC:4238-DB (Delhi High Court)
Facts of the
Case
The Revenue filed an appeal under Section 260A of the Income Tax
Act, 1961 against the order of the Income Tax Appellate Tribunal for Assessment
Year 2003-04.
The Assessing Officer had ...
Director of Income Tax vs. SNC Lavalin International Inc. – Whether Development and Transfer of Technical Plans Constitutes “Fees for Included Services” under Article 12(4)(b) of the India–Canada DTAA and Taxable at 15%
Facts of the CaseSNC Lavalin International Inc., a non-resident
Canadian company, was engaged in providing consultancy services for
infrastructure projects. The company entered into an agreement with the
National High...
Director of Income Tax vs. Mitsubishi Corporation & Connected Assessees | Section 234B Interest Not Leviable Where Income is Subject to TDS | Delhi High Court
Facts of the
Case
The Revenue preferred multiple appeals before the Delhi High Court.
The sole issue involved in all appeals was the applicability of
interest under Section 234B of the Income Tax Act.
The as...
Director of Income Tax vs. Mitsubishi Corporation & Connected Assessees (Delhi High Court) – No Interest under Section 234B Where Income is Subject to TDS | ITA Nos. 600/2008, 601/2008, 763/2008, 606/2009, 138/2010, 207/2010 & 208/2010
Facts of the
Case
The Revenue filed multiple appeals before the Delhi High Court.
The controversy in all the appeals related to the levy of interest
under Section 234B of the Income-tax Act, 1961.
The assess...
Commissioner of Income Tax vs Assessee (ITA Nos. 320/2008 & 321/2008) – Appeal Against Order Passed Under Section 254(2) Held Not Maintainable Under Section 260A of the Income-tax Act, 1961 | Delhi High Court
Facts of the
CaseThe appellant filed ITA Nos. 320/2008 and 321/2008
before the Delhi High Court challenging an order passed by the Income Tax
Appellate Tribunal under Section 254(2) of the Income-tax Act, 1961.The app...
Marubeni India Pvt. Ltd. v/s Commissioner of Income Tax: Scope of ITAT Jurisdictional Powers under Section 254(1) to Issue Binding Directions and Allowability of Expatriate Tax Reimbursements as Business Expenditure under Section 37(1)
Facts of the Case
Corporate
Restructuring: The appellant-assessee, Marubeni India
Private Limited, was incorporated as a wholly-owned domestic subsidiary of
Marubeni Corporation, Japan, taking over th...
Appeal Against ITAT Rectification Order Not Maintainable Under Section 260A – Commissioner of Income Tax vs Assessee | Delhi High Court
Facts of the CaseThe appeals before the Delhi High Court were filed
against an order passed by the Income Tax Appellate Tribunal (ITAT) under
Section 254(2) of the Income-tax Act, 1961. Section 254(2) empowers the
Tri...
Commissioner of Income Tax vs. Assessee Company – Valuation of Old and Shop-Spoiled Stock at Discounted Value Upheld | Delhi High Court
Facts of the
Case
The assessee maintained stock at its Connaught Place branch, which
included old and shop-spoiled inventory.
The assessee valued such stock at a discounted value considering
its reduced ...
Commissioner of Income Tax vs. Xerox Modicorp Limited: Whether Reopening of Assessment Under Section 147 is Valid and Admissibility of Investment Allowance Under Section 32A on Office Apparatus and Xerographic Machines Falling Under Schedule XI of the Income Tax Act, 1961
Facts of the Case
Assessee
Business Operations: The respondent-assessee, M/s. Xerox
Modicorp Limited, was actively engaged in the industrial operations of
manufacturing and selling xerographic machine...