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Commissioner of Income Tax (International Taxation)-2 vs Heidrick and Struggles Inc. – Rectification under Section 154 Not Denied for Wrong Head of Income Reporting (Delhi High Court)
Facts of the CaseThe respondent/assessee filed its return declaring income of
₹2.84 crore received for services rendered to an Indian entity under the head
“Income from Other Sources.”The return was processed und...
Cairnhill CGPE Limited & Anr. vs Commissioner of Income Tax (International Taxation)-2, New Delhi | Section 163 & 263 Income Tax Act Case
Facts of the Case
The
petitioners purchased shares of Mankind Pharmaceuticals Limited from Monet
Limited, a Mauritius-based entity.
The
transaction was governed by a Share Purchase Agreement dated ...
Cairnhill CGPE Limited & Cairnhill CIPEF Limited vs Commissioner of Income Tax (International Taxation)-2, New Delhi – Delhi High Court | Section 163 & 263 Income Tax Act
Facts of the CaseThe petitioners, Cairnhill CGPE Limited and Cairnhill CIPEF
Limited, had purchased shares of Mankind Pharmaceuticals Limited from Monet
Limited, a Mauritius-based entity. The transaction was governed b...
Pr. Commissioner of Income Tax-6 New Delhi vs Network Programme India Ltd – Reassessment u/s 147/148 Invalid Due to Change of Opinion & Absence of Tangible Material (AY 2002-03)
Facts of the CaseThe Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT), which had ruled in favour of the assessee. The reassessment
proceedings were initiated by the Assessing Officer (AO) on two...
Jindal Exports and Imports Pvt. Ltd. & Kiran Credits Pvt. Ltd. vs Deputy Commissioner of Income Tax Circle 13(1), Delhi & Ors. (Delhi High Court, 2023) – Invalidity of Section 148A(b) Notice Issued Beyond Prescribed Timeline
Facts of the CaseThe petitioners, Jindal Exports and Imports Pvt. Ltd.
and Kiran Credits Pvt. Ltd., challenged the legality of reassessment
proceedings initiated by the Income Tax Department.The challenge was specifica...
Jindal Exports and Imports Pvt. Ltd. & Anr. vs Deputy Commissioner of Income Tax Circle 13(1), Delhi & Ors. – Invalid Reassessment Notices under Section 148A(b) Quashed (Delhi High Court, 2023)
Facts of
the CaseThe present batch of writ petitions involved Jindal Exports
and Imports Private Limited and Kiran Credits Private Limited, who
challenged the legality of reassessment proceedings initiated by th...
Jindal Exports and Imports Pvt. Ltd. & Anr. vs Deputy Commissioner of Income Tax Circle 13(1), Delhi & Ors. – Delhi High Court Sets Aside Invalid Section 148A Notices Violating CBDT Timeline and Statutory Mandate
Facts of the Case
The
petitioners challenged reassessment notices issued under Section 148A(b)
and subsequent orders under Section 148A(d).
The
notices, though dated 02.06.2022, were actually serve...
Jindal Exports and Imports Pvt. Ltd. & Kiran Credits Pvt. Ltd. vs Deputy Commissioner of Income Tax Circle 13(1), Delhi & Ors.
Facts of the Case
The
petitioners, namely Jindal Exports and Imports Pvt. Ltd. and Kiran Credits
Pvt. Ltd., filed writ petitions challenging reassessment proceedings
initiated by the Income Tax Depart...
Timex Group USA Inc. vs Deputy Commissioner of Income Tax, International Taxation Circle 3(1)(1), New Delhi & Anr. (Delhi High Court, 2023)
Facts of the CaseThe petitioner, Timex Group USA Inc., a tax resident of the
United States, challenged reassessment proceedings initiated by the Income Tax
Department for Assessment Year 2019–20.The dispute arose fro...
PR. Commissioner of Income Tax-6 vs Nokia Solutions and Networks India Pvt. Ltd. – Delhi High Court | Section 145 & Revenue Recognition on Unearned Income
Facts of the Case
The
assessee, Nokia Solutions and Networks India Pvt. Ltd., received amounts
classified as unearned revenue, which were recognized in its
financial statements but offered to tax in s...