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Pepsi Foods Pvt. Ltd. (Now Merged with Pepsico India Holdings Pvt. Ltd.) vs Assistant Commissioner of Income Tax & Others – Delhi High Court on Constitutional Validity of Section 254(2A) of Income Tax Act Regarding Automatic Vacation of ITAT Stay Orders
Facts of the
Case
Various petitioners including Pepsi Foods Pvt. Ltd., Ericsson AB
and Aspect Software Inc. challenged the constitutional validity of the
third proviso to Section 254(2A) of the Income Tax ...
Pepsi Foods Pvt. Ltd. (Now Pepsico India Holdings Pvt. Ltd.) Vs. Assistant Commissioner of Income Tax & Others | Delhi High Court on Constitutional Validity of Section 254(2A) of the Income Tax Act and Extension of ITAT Stay Beyond 365 Days
Facts of the
CaseMultiple writ petitions including those filed by
Pepsi Foods Ltd., Pepsi Foods Pvt. Ltd., Ericsson AB and Aspect Software Inc.
were heard together by the Delhi High Court as they involved a common leg...
M/s Lahmeyer Holding GmbH vs Deputy Director of Income Tax, Circle 3(2) – Reassessment under Sections 147 & 148 on Business Restructuring and Transfer of Contracts Held Invalid Due to Change of Opinion | Delhi High Court
Facts of the
CaseM/s Lahmeyer Holding GmbH, a foreign company
formerly known as Lahmeyer International GmbH, undertook a restructuring
exercise on 16.08.2007. Under this arrangement, the petitioner transferred the
un...
Pepsi Foods Pvt. Ltd. (Now PepsiCo India Holdings Pvt. Ltd.) & Ericsson AB vs Assistant Commissioner of Income Tax & Others | Constitutional Validity of Section 254(2A) of the Income Tax Act on Extension of ITAT Stay Beyond 365 Days
Facts of the
Case
Various petitioners including Pepsi Foods Pvt. Ltd., Pepsi Foods
Ltd., Ericsson AB and Aspect Software Inc. had filed appeals before the
Income Tax Appellate Tribunal.
The Tribunal gran...
Pepsi Foods Pvt. Ltd. (Now Pepsico India Holdings Pvt. Ltd.) & Ericsson AB vs Assistant Commissioner/Deputy Commissioner of Income Tax & Others – Constitutional Validity of Section 254(2A) of the Income Tax Act Regarding Automatic Vacation of ITAT Stay Orders
Facts of the
Case
Various petitioners including Pepsi Foods Pvt. Ltd., Pepsi Foods
Ltd., Ericsson AB, and Aspect Software Inc. filed writ petitions raising a
common issue.
Each petitioner had obtained in...
The Liquidator Polymerland India Pvt. Ltd. vs Deputy Commissioner of Income Tax – Delhi High Court | Real Income Theory and Taxability of Accrued Interest | Sections 4 & 5 of Income Tax Act
Facts of the
CaseThe assessee, Polymerland India Pvt. Ltd., a joint
venture company, was undergoing liquidation proceedings before the Allahabad
High Court. During the normal course of business, the assessee had advan...
The Liquidator Polymerland India Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Connected Income Tax Appeal on Carry Forward of Losses and Return Filing Compliance under Section 139(3)
Facts of the Case
Polymerland India Pvt. Ltd., represented through its Liquidator,
filed appeals before the Delhi High Court against the order of the tax
authorities.
The dispute related to treatment of l...
The Liquidator Polymerland India Pvt. Ltd. vs Deputy Commissioner of Income Tax | Delhi High Court on Penalty Proceedings under Section 138(1) and Income Tax Liability During Liquidation
Facts of the
Case
Polymerland India Pvt. Ltd. was under liquidation and represented
by the Liquidator before the Court.
Appeals being ITA Nos. 269/2008 and 270/2008 were filed against
proceedings involvi...
Commissioner of Income Tax v. Honeywell International (India) Pvt. Ltd. & Commissioner of Income Tax-V v. Qualcomm India Pvt. Ltd. – Section 10A Income Tax Act | Set-Off of Losses of Eligible Units Against Profits of Other Units | Delhi High Court
Facts of the
Case
In CIT v. Honeywell International (India) Pvt. Ltd., the
assessee claimed a set-off of losses amounting to approximately
₹2,46,93,358 relating to a unit eligible for exemption under Sec...
Commissioner of Income Tax-I vs St. Vaswani Education Society – Delhi High Court on Section 11 Exemption, Corpus Donations, Section 13 Violation and Voluntary Contributions under Income Tax Act
Facts of the
CaseThe dispute related to Assessment Years 2001-02 and
2002-03. The Revenue filed appeals before the Delhi High Court challenging the
findings of the ITAT which had granted relief to St. Vaswani Educatio...