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Royalty to Parent Company Cannot Be Treated as ‘Nil’: Delhi High Court Upholds Arm’s Length Royalty in PCIT-8 v. Samsung India Electronics Pvt. Ltd. (2024)
Facts of the CaseSamsung India Electronics Pvt. Ltd. (STI), a wholly owned
subsidiary of Samsung Electronics Co. Ltd., Korea, was engaged in manufacturing
and selling mobile phones in India and overseas markets. Under ...
Genuine Export Proceeds Not Taxable as Undisclosed Income: Delhi High Court Upholds ITAT in PCIT v. Arun Malhotra (2024)
Facts of the CaseThe appeal arose from block assessment proceedings covering
the period 1 April 1989 to 14 July 1999 in the case of Arun Malhotra. The
matter had undergone multiple rounds of litigation before the Incom...
Capitation Fee by Educational Trust Defeats Charitable Status: Delhi High Court Denies Section 11 Exemption in PCIT (Central)-1 v. Maharaji Education Trust (2024)
Facts of the CaseThe Revenue challenged an order of the Income Tax Appellate
Tribunal (ITAT) which had declared reassessment proceedings under Section 148
invalid for Assessment Year 2007-08 in the case of Maharaji Edu...
No Addition Without Incriminating Material in Search Assessments: Delhi High Court Upholds ITAT in PCIT (Central)-2 v. Satya Prakash Gupta (2024)
Facts of the CaseThe Revenue challenged a common order of the Income Tax
Appellate Tribunal (ITAT) relating to Assessment Years 2012-13 to 2017-18 in
the case of the respondent, Shri Satya Prakash Gupta. The assessee, ...
Assessing Officer Must Give Full Effect to ITAT Relief: Delhi High Court Allows Deduction Claim in MUFG Bank Ltd. v. ACIT (2024)
Facts of the CaseMUFG Bank Ltd., the petitioner, challenged an order dated 13
May 2022 passed by the Assessing Officer (AO) denying deduction of
₹9,62,39,916. The impugned order was passed to give effect to a prior d...
Assessee Entitled to Raise Fresh Claims Before Tribunal Despite Return Filed: Delhi High Court Quashes Assessment in Mitsubishi Corporation v. ACIT (International Tax) (2024)
Facts of the CaseThe petitioner, Mitsubishi Corporation, a company incorporated
in Japan and a tax resident of Japan, challenged draft and final assessment
orders for AY 2005-06 passed by the Assessing Officer (AO). Th...
Reassessment Notice Beyond Limitation Invalid: Delhi High Court Quashes Section 148 Proceedings for AY 2016-17 in Manju Somani v. ITO Ward-70(1) (2024)
Facts of the
CaseThe petitioner
challenged the reassessment proceedings initiated by the Income Tax Department
for Assessment Year (AY) 2016-17 through notice dated 29 April 2024 issued
under Section 148 of the Incom...
Income Tax Settlement Commission Can Add Undisclosed Income Beyond Disclosure: Delhi High Court in Madhuri Dhanuka v. PCIT (2024)
Facts of the CaseA batch of writ petitions was filed by members of the Dhanuka
family, including individuals and HUFs, challenging a common order dated
26.06.2019 passed by the Income Tax Settlement Commission (ITSC). ...
Composite Sports Management Services Not Fully Taxable as FTS: Delhi High Court on PE Attribution & “Make Available” Test in International Management Group (UK) Ltd. v. CIT (International Taxation) (2024)
Facts of the CaseInternational Management Group (UK) Ltd. (IMG), a UK-based
entity, challenged orders of the Income Tax Appellate Tribunal concerning
Assessment Years 2010-11 to 2018-19. IMG had entered into a Memorand...
Reassessment Notice Issued in the Name of a Deceased Assessee Is Void Ab Initio; Proceedings Cannot Continue Without Notice to Legal Heirs under Section 159 – Dharmendra Deo Mishra (L/H of Late Kamal Mishra) vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Dharmendra Deo Mishra, is the legal
heir of Late Smt. Kamal Mishra, who expired on 18 April 2017. The
death of the original assessee was duly intimated to the Income Tax
Department on ...