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Higher TDS Certificate under Section 197 Quashed After ITAT Set Aside Finding of Permanent Establishment; Revenue Directed to Issue Certificate at 1.5% – GE Energy Parts Inc. vs. ACIT (Delhi High Court)
Facts of the
CaseThe writ petitions were filed by GE Energy Parts
Inc., USA and GE Global Parts and Products GmbH, Switzerland, challenging
certificates issued under Section 197 of the Income-tax Act, 1961 for Assessm...
Virtual Service PE Not Recognised under India-UK DTAA; Section 195 Nil Withholding Certificate Rejection Set Aside: Ernst and Young LLP vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Ernst and Young LLP, filed a writ
petition challenging the certificate and order dated 17.09.2025 passed under
Section 195 of the Income-tax Act, whereby the Assessing Officer directed...
Release of Seized Jewellery, Bullion and Cash Ordered on Deposit of Advance Tax Pending Section 158BC Proceedings – Dhirendra Vir Rastogi vs. ACIT Central Circle-27 (Delhi High Court)
Facts of the
CaseThe petitioner, Dhirendra Vir Rastogi, was one of
the family members forming part of a batch of writ petitions filed before the
Delhi High Court seeking release of movable assets seized during a searc...
TDS Liability under Section 194H Confirmed but Demand Restricted to Interest Only Where Agents Already Paid Tax: CIT Delhi XVII vs. Royal Jordanian Airlines (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal against the order
passed in favour of Royal Jordanian Airlines in relation to Assessment Year
2008-09, concerning non-deduction of tax at source on supplementary commission...
Review Petition Dismissed; No Error Apparent in Direction to Process Returns in Accordance with Law Despite Revenue’s Objections – Bechtel Limited vs. ACIT Circle 1(1)(2), New Delhi (Delhi High Court)
Facts of the
CaseA batch of writ petitions was filed by Bechtel
Limited and Bechtel Power Corporation challenging actions of the Income Tax
Department in relation to processing of income tax returns. The Delhi High
C...
Release of Seized Jewellery, Bullion and Cash Ordered on Deposit of Advance Tax Pending Section 158BC Proceedings – Aryaman Vir vs. ACIT Central Circle-27 (Delhi High Court)
Facts of the
CaseThe petitioner, Aryaman Vir, was one of the family
members forming part of a batch of writ petitions filed before the Delhi High
Court seeking release of movable assets seized during a search conducte...
Fraudulent ITC Recipient Case Not Entertained in Writ; Assessee Relegated to Statutory Appeal with Time Protection – Utkarsh Arora (M/s Aura Interior Hardware) vs. Additional Commissioner CGST (Delhi HC)
Facts of the CaseThe
petitioner, Utkarsh Arora, proprietor of M/s Aura Interior Hardware, filed a
writ petition under Article 226 challenging the Order-in-Original dated 27
January 2025, dispatched on 1 February 2025,...
GST Adjudication Order Set Aside Where SCN Was Uploaded Only on ‘Additional Notices’ Tab: Matter Remanded Subject to Section 168A Outcome – Techcoral Solutions vs. Commissioner of DGST (Delhi High Court)
Facts of the CaseThe
petitioner, Techcoral Solutions, filed a writ petition challenging the show
cause notice dated 26.09.2023 issued for Financial Year 2017-18 and the
consequent adjudication order dated 14.12.2023. ...
Reassessment Order under Section 148A Set Aside Where GST Proceedings on Same Transaction Closed Subsequently; Matter Remanded for Fresh Consideration – Vedanta Limited vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Vedanta Limited, filed a writ petition
challenging a notice dated 24.03.2025 issued under Section 148A(1) of the
Income-tax Act, 1961 and the consequent order dated 23.06.2025 passed un...
Fresh GST Registration Cannot Be Denied During Pendency of Appeal After Statutory Pre-Deposit: Section 107(7) Applied – Sarabjeet Singh vs. Commissioner of SGST (Delhi High Court)
Facts of the CaseThe
petitioner, Shri Sarabjeet Singh, proprietor of M/s Khurana Associates, had an
earlier GST registration which was cancelled following disruption of business
during the COVID-19 period. A show caus...