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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 ...
Vocational Skill Training Constitutes “Education” — Delhi High Court Upholds ITAT Order Quashing Section 263 Revision in CIT (Exemptions) vs NIIT Foundation (2024)
Facts of the CaseThe respondent-assessee, NIIT Foundation, is a society
registered under the Societies Registration Act, 1860, holding registration
under Section 12A and approval under Section 80G of the Income Tax Act...
Reassessment Notice Issued to a Deceased Assessee Is Void Ab Initio; Jurisdiction Cannot Be Assumed Without Notice to Legal Heirs – Chanchal Singh (Legal Heir of Rajeshwari Singh) vs ITO (Delhi High Court)
Facts of the CaseThe petitioner, Chanchal Singh, is the legal heir of Late
Rajeshwari Singh, who passed away on 24 May 2021. The fact of death
was duly intimated to the Income Tax Department on 27 July 2021.Despite suc...
Reassessment Cannot Travel Beyond Reasons Recorded Under Section 148A(b); Change of Stand Without Fresh Material Is Invalid – ATS Infrastructure Ltd. vs ACIT (Delhi High Court)
Facts of the CaseThe petitioner, ATS Infrastructure Limited, challenged
reassessment proceedings initiated under Section 148 of the Income-tax
Act, 1961 for Assessment Years 2014-15, 2015-16 and 2016-17. The
reassessm...
Reassessment Reopened by Corrigendum Without Fresh Tangible Material Is Unsustainable; Change of Opinion Impermissible – Aarti Fabricott Private Limited vs Income Tax Officer (Delhi High Court)
Facts of the CaseThe petitioner, Aarti Fabricott Private Limited, is a
company registered with the Registrar of Companies and a regular income-tax
assessee. For Assessment Year 2017–18, it filed its return of income ...