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Search Assessment Invalid Without Incriminating Material & Cross-Examination: Delhi High Court Dismisses Revenue Appeal in PCIT (Central)-3 v. Design Infracon Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed appeals challenging the order dated 04
October 2017 passed by the Income Tax Appellate Tribunal (ITAT) concerning
Assessment Year 2011-12 in respect of M/s Design Infracon Pvt. Ltd., ...
No Addition Under Section 68 Without Incriminating Material: Delhi High Court Dismisses Revenue Appeal in PCIT (Central)-3 v. Delicate Realtors Pvt. Ltd. (2024)
Facts of the CaseThe Revenue filed appeals challenging the order dated 04
October 2017 passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Year 2011–12 concerning M/s Pavitra Realcon Pvt. Ltd., M/s Deli...
Search Additions Cannot Be Based on Presumptions: Delhi High Court Upholds ITAT Deleting Section 68 & 69 Additions in PCIT (Central)-3 v. GTM Builders & Promoters Pvt. Ltd. (2024)
Facts of the
CaseThe Revenue filed
multiple appeals against orders of the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2006-07 and 2007-08 relating to M/s GTM Builders
& Promoters Pvt. Ltd. an...
Reassessment After 4 Years Invalid Without Fresh Tangible Material: Delhi High Court Dismisses Revenue Appeal in PCIT Delhi-8 v. Samsung India Electronics Pvt. Ltd. (2024)
Facts of the CaseThe Revenue appealed against the order of the Income Tax
Appellate Tribunal (ITAT) dated 23 February 2018, which invalidated
reassessment proceedings for Assessment Year 2002-03 on the ground that they...
Bank Account Freeze Cannot Continue Beyond 60 Days Without Fresh Order: Delhi High Court Orders Defreezing in M/s Pooja Trading Co. v. DDIT (Investigation) (2024)
Facts of the CaseThe petitioners sought directions to defreeze their bank
accounts and to set aside a letter dated 30 April 2023 issued by the Income Tax
Department. The accounts had been frozen while calling for infor...
Corporate Guarantee Fee Not ‘Interest’ but Taxable as Other Income in India: Delhi High Court in Johnson Matthey PLC v. CIT (International Taxation)-2 (2024)
Facts of the CaseJohnson Matthey PLC, a tax resident of the United Kingdom and
engaged in manufacturing specialty chemicals, had provided parent company
guarantees to overseas branches of foreign banks in relation to c...
Penalty Immunity Wrongly Denied Without Specific Charge: Delhi High Court Quashes Section 270A Notices in GE Capital US Holdings Inc. v. DCIT (International Taxation) (2024)
Facts of the CaseThe petitioner challenged orders dated 28 December 2021 and 24
January 2022 rejecting its applications under Section 270AA(4) of the Income
Tax Act, 1961 seeking immunity from penalty. The petitioner a...
Transfer of Assessment Valid for Coordinated Investigation: Delhi High Court Upholds Centralisation Under Section 127 in Dollar Gulati v. PCIT (2024)
Facts of the CaseThe petitioners challenged orders dated 20 February 2024 and
11 March 2024 passed under Section 127 of the Income Tax Act, 1961, whereby
their cases were transferred from the jurisdictional Assessing O...
Reassessment Notice Time-Barred in Search Case: Delhi High Court Quashes Section 148 Action Beyond 10-Year Limit in Dinesh Jindal v. ACIT (2024)
Facts of the CaseThe petitioner challenged the initiation of reassessment
proceedings under Section 148 of the Income Tax Act, 1961 for Assessment Year
2013-14. The impugned action was based on a search conducted on 9 ...
Charitable Trust Entitled to 15% Accumulation on Deemed Income: Delhi High Court Upholds Section 11 Benefit in CIT (Exemptions) v. Jamnalal Bajaj Foundation (2024)
Facts of the CaseThe Revenue appealed against the decision of the Income Tax
Appellate Tribunal (ITAT) which had allowed the assessee—Jamnalal Bajaj
Foundation, a registered charitable trust—the benefit of accumula...