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Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fee Taxability, PE Profit Attribution & Section 234B Interest
Facts of the
CaseThe appeals were filed by the Revenue against a
common order passed by the Income Tax Appellate Tribunal concerning Assessment
Years 2013-14 to 2016-17. The dispute pertained to the taxability of inco...
PR. Commissioner of Income Tax (Central)-2 vs M/s Jay Ambey Aromatics (Delhi High Court) – Section 153A Additions Without Incriminating Material Not Sustainable
Facts of the
CaseThe Revenue filed multiple appeals challenging a common
order dated 15 July 2021 passed by the Income Tax Appellate Tribunal (ITAT)
relating to Assessment Years 2008-09 to 2011-12. The ITAT had delete...
PR. Commissioner of Income Tax-1 vs M/s Bechtel India Pvt. Ltd. | Delhi High Court | Transfer Pricing – Comparable Selection & Functional Dissimilarity under Section 260A
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court challenging the order of the Income Tax Appellate Tribunal
(ITAT) dated 18.12.2020 for Assessment Year 2013–14. The assessee, ...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – Booking Fees Not Royalty | Section 195 & 234B | PE Profit Attribution @15%
Facts of the
CaseThe present matter concerns multiple appeals filed
by the Revenue for Assessment Years 2013–14, 2014–15, 2015–16, and 2016–17
against a common order dated 29.01.2021 passed by the Income Tax A...
PR. Commissioner of Income Tax (Central)-2 vs M/s Jay Ambey Aromatics – Section 153A Additions Without Incriminating Material Not Sustainable (Delhi High Court)
Facts of the CaseThe Revenue filed
multiple appeals before the Delhi High Court challenging a common order
passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2008-09 to 2011-12.The ITAT had
delet...
Commissioner of Income Tax (International Taxation)–1 vs Amadeus IT Group SA (Delhi High Court) – PE Attribution, Royalty vs Business Income & Section 234B Interest
Facts of the
CaseThe 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 to 2016-17. The dispute revolved around th...
Mittal International vs Assistant Commissioner of Income Tax, Circle 52(1), New Delhi (Delhi High Court) – Reassessment Proceedings on Deactivated PAN under Sections 148 & 148A(d) of Income Tax Act
Facts of the
CaseThe petitioner challenged the validity of an order
passed under Section 148A(d) and a consequential notice issued under Section
148 for Assessment Year 2016–17. The primary contention was that the e...
Omesh Jain vs Income Tax Officer Ward 46(1), Delhi (Delhi High Court, 2022) – Challenge to Reassessment Proceedings under Sections 148 & 148A(d) of the Income Tax Act, 1961
Facts of the
CaseThe present writ petition was filed challenging the
order passed under Section 148A(d) of the Income Tax Act, 1961, along
with the consequential notice issued under Section 148, both dated 31
March 2...
Victorious H Grand vs Pr. Commissioner of Income Tax & Anr. (Delhi High Court, 2023) – Delay in Disposal of Revision Application under Section 264 of Income Tax Act
Facts of the
CaseThe petitioner filed a revision application under
Section 264 of the Income Tax Act, 1961 around 20.02.2020, challenging an
assessment order dated 21.12.2019 passed under Section 144 of the Act. Howev...
Commissioner of Income Tax (International Taxation)-3 vs Radisson Hotel Interaction Inc. | Delhi High Court | Section 9(1)(vii) | FTS vs Centralized Services under Indo-US DTAA
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order passed by the Income Tax Appellate Tribunal (ITAT) for
Assessment Year 2016–17. The dispute pertained to payments received by the
a...