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Reassessment for AY 2015-16 Quashed Following Revenue’s Concession in Rajeev Bansal; Notices Issued After 01.04.2021 Not Sustainable: Rajiv Kumar Khandelwal vs. DCIT (Delhi HC)
Facts of the CaseThe petitioner, Rajiv Kumar Khandelwal, is an
individual who filed his return of income for Assessment Year 2015-16 on
30.09.2015 declaring an income of ₹1,36,81,160. The Assessing Officer issued a
...
Reassessment Sustained Where Section 148 Notice Digitally Signed on 31.03.2021 but Issued on 01.04.2021 Attracts Ashish Agarwal Regime: Rajesh Chopra vs. ITO (Delhi HC)
Facts of the CaseThe petitioner, Rajesh Chopra, an individual
resident of New Delhi, filed his return of income for Assessment Year 2013-14
on 08.08.2013 declaring total income of ₹20,59,151. A notice dated 31.03.202...
DCF Valuation Substantiated by Expert Cannot Be Rejected on Generic Disclaimers; Section 56(2)(viib) Addition Set Aside – PCIT-1 vs. A.H. Multisoft Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 05.07.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2016–17. The Tribunal...
Section 153A Assessment Without Incriminating Material Unsustainable; Kabul Chawla and Abhisar Buildwell Applied – PCIT-1 vs. Charvak Trading Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 16.06.2023 passed by the
Income Tax Appellate Tribunal for Assessment Year 2010–11. The Tribunal...
Repair and Maintenance Services of Aircraft Equipment Do Not “Make Available” Technical Knowledge; Receipts Not Taxable as FTS/FIS under India–US DTAA – PCIT (International Taxation) vs. Goodrich Corporation (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 22.08.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2018–19. The Tribunal...
Protective Additions Under Section 68 Not Sustainable Once Substantive Additions Made in Hands of Beneficiaries; Shell Conduit Cannot Be Taxed – PCIT, Delhi-7 vs. Third Generation Traders Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed multiple appeals under Section
260A of the Income-tax Act, 1961 challenging a common order dated 20.09.2024
passed by the Income Tax Appellate Tribunal for Assessment Years 2012-13 to...
Addition on Alleged Bogus Purchases and Sales Leads to Double Taxation Where Income Already Offered; Section 145(3) Not Properly Invoked – PCIT (Central), Ludhiana vs. Garg Acrylics Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the common order dated 27.10.2020 passed
by the Income Tax Appellate Tribunal for Assessment Year 2011–12. The T...
Form 26AS Mismatch Due to Apparent Errors Not “Tangible Material” for Reopening; Reassessment Based on Erroneous TDS Data Invalid – PCIT vs. Sanjay Pratap Singh (Delhi High Court)
Facts of the CaseThe assessee, Sanjay Pratap Singh, filed his
return of income for Assessment Year 2009–10 on 25.07.2009 declaring total
income of ₹10,92,498/-, comprising salary income and income from other source...
Reopening Beyond Four Years Invalid Without Allegation of Failure to Disclose Material Facts; Section 147 Jurisdiction Fails in Share Capital Case – PCIT vs. K.R. Pulp and Papers Ltd. (Delhi High Court)
Facts of the CaseThe assessee, M/s K.R. Pulp and Papers Ltd., a
public limited company engaged in manufacturing kraft and brown paper, filed
its return of income for Assessment Year 2009–10 on 26.09.2009 declaring in...
Reassessment Notice for AY 2013–14 Issued Beyond Residual Limitation under Section 149 Quashed; Computation Governed by Rajeev Bansal and Ram Balram Buildhome – Parveen Kumar Malhotra vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Parveen Kumar Malhotra, filed a
writ petition challenging the order dated 28.07.2022 passed under Section
148A(d) of the Income-tax Act, 1961 and the consequential notice dated
29.07.2...