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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...
Sanjiv vs. ACIT (ITAT): Tribunal Decision on Assessment Additions and Appellate Relief — Findings under Relevant Provisions of the Income-tax Act
Facts of the CaseThe assessee, Sanjiv, was subjected to assessment
proceedings in which the Assessing Officer made certain additions to the
declared income. The assessee challenged these additions before the
Commissio...
Completed Reassessment Cannot Be Reopened Under Ashish Agarwal: Delhi High Court Quashes Fresh Section 148 Proceedings in Akshita Jindal v. ITO (2024)
Facts of the CaseThe petitioner challenged the notice dated 1 June 2022 issued
under Section 148A(b), the order dated 16 July 2022 passed under Section
148A(d), and the consequent notice dated 16 July 2022 under Sectio...
Reassessment Upheld for Non-Disclosure of Material Facts: Delhi High Court Validates Section 147 Action in BDR Builders & Developers Pvt. Ltd. v. ACIT (2024)
Facts of the CaseThe petitioner company challenged a notice dated 31 March 2018
issued under Section 148 of the Income Tax Act, 1961 and the subsequent order
dated 25 September 2018 under Section 148A(d) for Assessment...
ITAT Dismisses Revenue Appeals on Account of Low Tax Effect — CBDT Monetary-Limit Circular Binding | ACIT vs M/s Vindhyawasini (AYs Covered) | Section 268A of Income-tax Act
Facts of the
CaseThe Revenue filed appeals before the Income Tax
Appellate Tribunal (ITAT), Allahabad Bench, challenging the orders passed by
the Commissioner of Income Tax (Appeals) in favour of the assessee for the
...