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Reassessment for AY 2015–16 Quashed as Time-Barred under First Proviso to Section 149: Manju Somani Ratio Applied – Gopal Bansal vs. ACIT (Delhi High Court)
Facts of the CaseThe petitioner, Gopal Bansal, challenged
the order dated 31.08.2024 passed under Section 148A(d) of the Income-tax Act,
1961 and the consequential notice issued under Section 148 of the Act for
Assess...
Retention of Seized Jewellery Beyond 120 Days Without Statutory Satisfaction Upheld; No Automatic Release under Section 132B – Rajesh Gupta & Ors. vs. ACIT (Delhi HC)
Facts of the CaseA search and seizure operation under Section 132 of the
Income-tax Act, 1961 was conducted at the residential and office premises of
the petitioners between 09.10.2024 and 11.10.2024. During the search...
TDS Default under Section 276B Established Despite Subsequent Deposit: Acquittal Set Aside and Sentence Modified to Admonition – ITO vs. Great Indian Nautanki Co. Pvt. Ltd. (Delhi High Court)
Facts
of the CaseA
complaint was filed by the Income Tax Department against the respondent company
for failure to deposit tax deducted at source for Financial Year 2012–13 within
the prescribed time, in violation o...
Transfer Pricing Adjustment on Intra-Group Services Deleted on Grounds of Consistency and Factual Findings; No Substantial Question of Law – PCIT Delhi-1 vs. Avery Dennison (India) Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 05.06.2023 passed by the
Income Tax Appellate Tribunal in ITA Nos. 7960/Del/2019 and 7961/Del/2019...
Reassessment Proceedings Set Aside for Non-Consideration of Reply and Reopening on Identical Issue Already Examined: Matter Remanded under Section 148A – Logix Heights Pvt. Ltd. vs. DCIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Logix Heights Private Limited, filed a writ petition challenging
the notice dated 29.03.2025 issued under Section 148A(1) of the Income-tax Act,
1961, the order dated 30.06.2025 passe...
Reassessment Proceedings Upheld Where Independent Verification Established Escapement of Income: No Interference at Section 148A Stage – Harshit Finvest Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Harshit Finvest Pvt. Ltd., a Non-Banking Financial Company
registered with the Reserve Bank of India, challenged the order dated
30.06.2025 passed under Section 148A(3) of the Income-...
Transfer Pricing Adjustment Deleted Where ITAT Found Actual Receipt of Intra-Group Services and Faulted DRP for Non-Application of Mind; No Substantial Question of Law – PCIT Delhi-1 vs. BorgWarner Emissions Systems India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe assessee, BorgWarner Emissions Systems India Private Ltd.,
is engaged in manufacturing and marketing Exhaust Gas Recirculation (EGR)
systems and components for the automotive industry, with its reg...
Licence Fee Paid for Use of Goodwill Not Prohibited by Law; Bar Council Rules Not Attracted; Revenue Appeals Dismissed – PCIT-21 vs. Remfry & Sagar (Delhi HC)
Facts of the CaseThe Revenue filed multiple appeals under Section 260A of the
Income-tax Act, 1961 against a common assessee, M/s Remfry & Sagar, for
different assessment years. The assessee, a law firm, had paid l...
Transfer Pricing Royalty Benchmarking under CUP Sustained; Selection of Comparables a Pure Question of Fact – PCIT-7 vs. Tupperware India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed two appeals under Section 260A of the
Income-tax Act, 1961 challenging a common order dated 12.03.2025 passed by the
Income Tax Appellate Tribunal in ITA No. 9727/Del/2019 for Assessm...
No Addition under Section 153A for Unabated Years Without Incriminating Material; Revenue Appeal Dismissed Following Abhisar Buildwell – PCIT-1 vs. Mirage Homes Pvt. Ltd. (Delhi HC)
Facts of the CaseA search under Section 132 of the Income-tax Act, 1961 was
conducted in the case of the assessee group. For Assessment Year 2004–05, the
Assessing Officer completed assessment under Section 153A maki...