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Commissioner of Income Tax (International Taxation)-2 vs Net App B.V. – Taxability of Software Subscription Receipts as Royalty under Section 9(1)(vi) of the Income Tax Act read with Article 12 of India-Netherlands DTAA | Section 234B Interest Liability
Facts of the CaseThe present matter arose from two appeals filed by
the Revenue before the Delhi High Court against the order of the Income Tax
Appellate Tribunal (ITAT) concerning Assessment Years 2008-09 and 20...
Principal Commissioner of Income Tax–7 vs. Bikram Singh | Delhi High Court | Section 68 of the Income-tax Act, 1961 | Unexplained Cash Credits, Identity, Creditworthiness & Genuineness of Loan Transactions
Facts of the CaseThe assessee filed his income tax return for Assessment Year
2011–12 declaring income of ₹80,45,590.During assessment proceedings, the Assessing Officer noticed
unsecured loans/advances aggregating...
Pr. Commissioner of Income Tax-06 vs Modi Apollo International Group (P) Ltd. | Delhi High Court on Section 195 TDS, Fee for Technical Services (FTS) & Royalty Payment under Income Tax Act
Facts of the
CaseThe Revenue preferred appeals against the common
order passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2007-08 and 2009-10.The assessee had made payments to Apollo
Internation...
Pr. Commissioner of Income Tax-06 v. Modi Apollo International Group (P) Ltd. | Delhi High Court | Section 195 TDS on Foreign Payments and Royalty Expenditure under the Income Tax Act, 1961
Facts of the
CaseThe Revenue filed two appeals before the Delhi High
Court against a common order passed by the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2007-08 and 2009-10. The dispute arose o...
Pr. Commissioner of Income Tax-16 vs Jagat Talkies Distributors | Non-Supply of Reasons Recorded under Section 148 Invalidates Reassessment Proceedings | Delhi High Court
Facts of the CaseThe assessee, Jagat Talkies Distributors, was engaged in the
business of film exhibition and also earned rental income from letting out
property. For Assessment Years 1999-2000 to 2004-2005, the assess...
Principal Commissioner of Income Tax, Delhi-2 vs Best Infrastructure (India) Pvt. Ltd. – Whether Statement Recorded Under Section 132(4) Constitutes Incriminating Material for Addition Under Section 68 and Assessment Under Section 153A?
Facts of the CaseA search and seizure operation under Section 132
was conducted in the case of the Best Group of Companies and one Tarun Goyal.
During the search, the Revenue recovered loose papers and documents allege...
Principal Commissioner of Income Tax-16 vs Jagat Talkies Distributors | Non-Supply of Reasons Recorded Under Section 148 Held Fatal to Reassessment Proceedings | Delhi High Court
Facts of the CaseThe assessee, Jagat Talkies Distributors, was engaged in the
business of film exhibition and also earned rental income from letting out
property to banks. For Assessment Years 1999-2000 to 2004-2005, n...
Principal Commissioner of Income Tax, Delhi-2 vs. Best Infrastructure (India) Pvt. Ltd. & Connected Matters | Delhi High Court | Section 68 & Section 153A of Income Tax Act | Addition on Basis of Search Statements and Incriminating Materia
Facts of the
CaseThe Revenue filed appeals before the Delhi High
Court against the common order passed by the ITAT concerning multiple companies
belonging to the Best Group for Assessment Years 2005-06 to 2009-10.A se...
Principal Commissioner of Income Tax-16 vs Jagat Talkies Distributors – Delhi High Court on Mandatory Supply of Reasons in Reassessment Proceedings under Sections 147 & 148 of the Income-tax Act | ITA No. 916/2015 (2017)
Facts of the CaseThe Revenue initiated reassessment proceedings against the
assessee, Jagat Talkies Distributors, alleging escapement of taxable income for
the relevant assessment years. Notices under Section 148 were ...
Principal Commissioner of Income Tax, Delhi-2 vs Best Infrastructure (India) Pvt. Ltd. & Connected Matters | Delhi High Court | Section 68 & Section 153A Income Tax Act | Addition on Alleged Accommodation Entries and Scope of Incriminating Material
Facts of the CaseA search and seizure operation under Section 132
was conducted on the Best Group of Companies and related persons on 15
September 2008. During the search, loose papers and documents were found, which
...