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M/s Asian Hotels Ltd. vs Commissioner of Income Tax – Deductibility of Renovation & Consultancy Expenses under Section 37 of Income Tax Act
Facts of the
CaseThe appellant, M/s Asian Hotels Ltd.,
incurred expenditure towards renovation, repair, and refurbishment of its
existing hotel property.A sum of ₹11,00,000 was paid to Gherzi
Eastern Ltd. (GEL) for...
Principal Commissioner of Income Tax-4 vs GE India Business Services Pvt. Ltd. (Delhi High Court) – Transfer Pricing Issues Covered by Rampgreen Solutions Case
Facts of the
Case
The appeal was preferred by the Revenue against the ITAT order.
The dispute relates to transfer pricing adjustments for AY 2009–10.
The Revenue aimed to challenge the Tribunal’s findi...
Principal Commissioner of Income Tax-3 vs Fujitsu India Pvt. Ltd. – RPM vs TNMM in Transfer Pricing for Pure Distributor (Delhi High Court)
Facts of the
CaseThe assessee, Fujitsu India Pvt. Ltd., was engaged
in distribution activities, purchasing goods from its associated enterprises
(AEs) and reselling them in India without any value addition.The Transfe...
PR. Commissioner of Income Tax-3 vs Fujitsu India Private Limited (Delhi High Court) – Applicability of Resale Price Method (RPM) vs TNMM for ALP Determination under Sections 144C & 143(3)
Facts of the
CaseThe case pertains to Assessment Years 2011-12,
2012-13, and 2013-14, where the Assessing Officer passed orders under Section
144C read with Section 143(3). The Transfer Pricing Officer (TPO) determine...
PR. Commissioner of Income Tax–3 vs Fujitsu India Pvt. Ltd. | Delhi High Court | Section 144C r/w 143(3) | Transfer Pricing – RPM vs TNMM for ALP Determination
Facts of the
CaseThe present matter pertains to appeals filed by the
Revenue against Fujitsu India Private Limited for Assessment Years 2011–12,
2012–13, and 2013–14.The Assessing Officer (AO) passed assessment ...
The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)
Facts of the CaseThe Revenue filed an appeal against the order of
the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the
Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...
The Pr. Commissioner of Income Tax-15 vs Madhu Gupta | Delhi High Court | Section 148 Notice Invalid Due to Improper Service | ITA 286/2022 (AY 2007-08)
Facts of the CaseThe Revenue filed an appeal against the order of
the Income Tax Appellate Tribunal (ITAT), which upheld the findings of the
Commissioner of Income Tax (Appeals) [CIT(A)].The core issue revolved around ...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Cobra Instalaciones y Servicios S.A | Delhi High Court | Engineering Fees Disallowance | Transfer Pricing & ALP
Facts of the
Case
The respondent/assessee incurred engineering expenses for execution
of a project related to Delhi Metro Rail Corporation (DMRC).
The assessee paid engineering fees to its head office.
The...
Mehra Jewel Palace Pvt. Ltd. vs Pr. Commissioner of Income Tax – Section 40A(2)(b) Disallowance & Opportunity of Hearing (Delhi High Court)
Facts of the
CaseThe assessee, Mehra Jewel Palace Pvt. Ltd., filed
appeals before the Delhi High Court challenging orders of the Income Tax
Appellate Tribunal for AY 2011–12 and AY 2012–13. Two primary issues aros...
PR. Commissioner of Income Tax, Delhi-7 vs Techno Trexim (India) Pvt. Ltd. | Section 14A r/w Rule 8D – No Disallowance in Absence of Exempt Income (Delhi High Court)
Facts of the
CaseThe present appeal was filed by the Revenue against
the order dated 05.09.2022 passed by the Income Tax Appellate Tribunal
concerning Assessment Year 2015–16.The Tribunal had deleted the disallowanc...