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Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fees Taxability, PE Profit Attribution & Section 234B Interest
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court concerning Assessment Years 2007–08, 2008–09,
2010–11, and 2011–12. The appeals arose from a common order dated 26.10....
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA – No Substantial Question of Law Where Issues Covered by Supreme Court & HC Precedents | Sections 195 & 234B | Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against a common order dated 26.10.2020 passed by
the Income Tax Appellate Tribunal concerning Assessment Years 2007-08, 2008-...
Cluster Overseas Private Limited vs Income Tax Officer Ward 6(1), Delhi (Delhi High Court, 2022) – Section 148 Notice Validity, Date of Issuance & Reassessment Proceedings
Facts of the
CaseThe Petitioner, Cluster Overseas Private Limited,
filed a writ petition challenging the legality of notices dated 31st March
2021 issued under Section 148 of the Income Tax Act, 1961 for Assessment
Y...
Vikram Bhatnagar (Legal Representative of Late Virendra Kumar Bhatnagar) vs Assistant Commissioner of Income Tax – Invalid Assessment Proceedings Against Deceased Assessee under Sections 143(2), 143(3), 156 & 270A of Income Tax Act, 1961
Facts of the
CaseThe petitioner, Vikram Bhatnagar, acting as the
legal representative of Late Shri Virendra Kumar Bhatnagar, challenged the
validity of assessment proceedings initiated by the Income Tax Department for...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – PE Attribution, Royalty vs Business Income & Section 195/234B Clarified
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court concerning Assessment Years 2007–08, 2008–09,
2010–11, and 2011–12. These appeals arose from a common order dated 26.1...
PR. Commissioner of Income Tax (Central)-2 vs M/s Jay Ambey Aromatics (Delhi High Court) – Section 153A Addition Without Incriminating Material Not Sustainable
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order of the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Years 2008-09 to 2011-12. The ITAT had delet...
Deepak Kapoor vs Principal Commissioner of Income Tax-2, New Delhi & Ors. | Delhi High Court | Reopening of Assessment u/s 147/148 on Change of Opinion – Capital Gains Dispute
Facts of the
CaseThe petitioner, Deepak Kapoor (assessee),
challenged a reassessment notice issued under Section 148 of the Income Tax
Act, 1961 for Assessment Year 2016–17. The notice alleged that income had
escap...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fee Taxability as Business Income, PE Profit Attribution @15%, and Non-Applicability of Interest u/s 234B where TDS Deductible
Facts of the CaseThe present appeals were filed by the Revenue
against a common order dated 29.01.2021 passed by the Income Tax Appellate
Tribunal concerning Assessment Years 2013-14, 2014-15, 2015-16, and 2016-17. The...
International Tractors Ltd. vs Deputy Commissioner of Income Tax (LTU) & Anr. – Section 250(4) & 80JJAA | Delhi High Court Allows Deduction, Sets Aside ITAT Remand
Facts of the
CaseThe assessee, International Tractors Ltd., filed an
appeal before the Delhi High Court challenging the order of the Income Tax
Appellate Tribunal (ITAT), which had set aside the relief granted by the
...
PR. Commissioner of Income Tax (Central)-2 vs. M/s Jay Ambey Aromatics (Delhi High Court) – Section 153A | No Addition Without Incriminating Material in Search Cases
Facts of the
Case
The Revenue filed multiple appeals challenging a common order of
the ITAT dated 15.07.2021.
The ITAT had deleted additions made by the Assessing Officer for
AYs 2008-09 to 2011-12.
...