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Section 153C Notices Invalid Without AY-Specific Incriminating Material — Delhi High Court in Naresh Mittal vs ITO Ward 43(6), Delhi & Ors., WP(C) 1112/2024 & Connected Matters (09 April 2024)
Facts of the CaseThe writ petitions formed part of a batch challenging notices
issued under Section 153C of the Income Tax Act, 1961 to assessees who were not
subjected to the original search. The petitioners contended...
Delhi High Court on Section 153C Jurisdiction: Proceedings Against Non-Searched Person Invalid Without Year-Specific Incriminating Material — Modicare Limited vs DCIT (Central Circle-14), WP(C) 3007/2023 & Connected Matters (09 April 2024)
Facts of the CaseThe present petitions formed part of a batch challenging
notices issued under Section 153C of the Income Tax Act, 1961 to assessees who
were not subjected to the original search proceedings. The petiti...
Delhi High Court Quashes Section 153C Notices Without AY-Specific Incriminating Material — Mamta Agarwal vs ACIT (Central Circle-28), WP(C) 792/2024 & Connected Matters (09 April 2024)
Facts of the CaseThe writ petitions formed part of a batch challenging notices
issued under Section 153C of the Income Tax Act, 1961 to assessees who were not
subjected to the original search. The petitioners contended...
Section 153C Proceedings Invalid Without AY-Specific Incriminating Material — Delhi High Court in Chander Parkash Gupta vs ACIT, Circle 43(1), Delhi & Ors., WP(C) 1763/2024 & 1802/2024 (09 April 2024)
Facts of the CaseThe writ petitions challenged notices issued under Section
153C of the Income Tax Act, 1961 to assessees who were not subjected to the
original search. The petitioners asserted that no incriminating ma...
Section 153C Notices Quashed Without AY-Specific Incriminating Material — Delhi High Court in Ashutosh Agarwal vs ACIT (Central Circle-28), WP(C) 992/2024 & Connected Matters (09 April 2024)
Facts of the CaseA batch of writ petitions challenged notices issued under
Section 153C of the Income Tax Act, 1961 to assessees who were not subjected to
the original search. The petitioners contended that no incrimin...
Delhi High Court on Section 153C: Notices Invalid Without AY-Specific Incriminating Material — Ashutosh Agarwal vs ACIT (Central Circle-28), WP(C) 992/2024 & Connected Matters (2024)
Facts of the CaseThe batch of writ petitions challenged notices issued under
Section 153C of the Income Tax Act, 1961 to various assessees who were not the
searched persons. The petitioners contended that no incriminat...
Section 68 Additions Unsustainable When Identity, Creditworthiness & Genuineness Proved: Delhi High Court Dismisses Revenue Appeal in PCIT-9 v. Topline Buildtech Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed an appeal under Section 260A of the Income
Tax Act, 1961 challenging the order dated 13.04.2018 of the Income Tax
Appellate Tribunal (ITAT) for Assessment Year 2013-14.The respondent-...
ACIT, Allahabad vs. Mr. Denzil Richard Innis, St. John’s Co-Ed School (ITAT Allahabad): Revenue Appeals Dismissed on Low Tax Effect under CBDT Circular No. 3/2018 — Section 268A of the Income-tax Act
Facts of the CaseThe Revenue filed multiple appeals before the
Income Tax Appellate Tribunal, Allahabad challenging the orders passed by the
Commissioner of Income Tax (Appeals), Allahabad in respect of the block...
Interest from Head Office to Indian Branch Not Taxable: Delhi High Court Applies “No Profit from Self” Principle in CIT (IT)-3 v. Bank of Tokyo-Mitsubishi UFJ Ltd. (2024)
Facts of the CaseThe Revenue challenged the order of the Income Tax Appellate
Tribunal dated 30 January 2018 concerning Assessment Year 2003-04. The dispute
centered on whether interest received by the Indian Permanent...
No Writ Relief When Adequate Opportunity Given: Delhi High Court Upholds Section 153C Assessment in Sunita Goel v. DCIT Central Circle-1 (2024)
Facts of the CaseThe petitioner challenged the assessment order dated
22.04.2021 passed under Section 153C of the Income Tax Act, 1961 for Assessment
Year 2014-15, whereby ₹1,62,20,000 was added to her income.The pet...