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Commissioner of Income Tax vs. Shri Francis Wacziarg – Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c) of the Income Tax Act, 1961
Facts of the Case
Multiple
appeals, including ITA No. 1170/2005 filed by the Commissioner of Income
Tax against Shri Francis Wacziarg, were pending before the Delhi High
Court.
The
appeals inv...
M/s Mignum Power Generation Ltd. vs. Additional Commissioner of Income Tax: Accrual of Interest Income under Mercantile System vs. Sticky Debt Claims under Section 5 of the Income Tax Act, 1961
Facts of the Case
Inter-Corporate
Deposit (ICD): The Assessee, M/s Magnum Power Generation
Ltd., advanced an inter-corporate deposit of ₹1 Crore on September 22,
1995, to M/s Padmini Polymer Ltd. (P...
Commissioner of Income Tax vs. M/s. Ambassador Hotel | TDS on Tips Distributed to Employees under Section 192 vs Section 201 Default
Facts of the CaseThe revenue preferred multiple
appeals (ITA Nos. 778/2008 to 780/2008, 814/2008 & 816/2008) against the
common order of the Income Tax Appellate Tribunal (ITAT) dated July 27, 2007,
for the ...
M Commissioner of Income Tax vs. M/s Britika Exports (P) Ltd. | Delhi High Court on Recording of Satisfaction for Penalty Proceedings under Section 271(1)(c)
Facts of the Case
The
Revenue filed appeals against orders passed by the Income Tax Appellate
Tribunal.
The
Tribunal had confined its examination to the issue of recording of
satisfaction for ...
Commissioner of Income Tax, Delhi-XVII vs. M/s NHK Japan Broadcasting Corporation: Whether Assessment and Penal Action Under Sections 201(1) and 201(1A) of the Income Tax Act, 1961 Can Be Initiated Beyond a Reasonable Limitation Period of Four Years in the Absence of a Statutory Time Limit
Facts of the Case
The
Respondent-Assessee is a foreign government-owned company operational
within India.
The
Assessee paid its Indian employees their regular salaries in Indian Rupees
(on wh...
Commissioner of Income Tax vs. [Assessee Name] | Appeal Becomes Infructuous After Tribunal Recalls Original Order Under Section 254(2) of Income Tax Act
Facts
of the CaseThe appellant filed an appeal (ITA
No. 244/2008) before the Hon’ble Delhi High Court challenging the order of the
Income Tax Appellate Tribunal (ITAT) dated August 9, 2007, passed in ITA No.
2248/D...
Commissioner of Income Tax, Delhi-VI, New Delhi vs. Virgo Marketing (P) Ltd. – Valid Satisfaction for Initiation of Penalty under Section 271(1)(c) of the Income Tax Act
Facts of the CaseThe Revenue challenged the order dated 26 April 2007 passed by
the Income Tax Appellate Tribunal, Delhi Bench ‘C’, concerning Assessment Years
2000-01, 2001-02 and 2002-03.The dispute related to wh...
Commissioner of Income Tax, Delhi-XVII vs. NHK Japan Broadcasting Corporation: Time Limit for Initiating Proceedings Under Section 201 and declaring Assessee-in-Default for Non-Deduction of TDS on Global Salary under Income Tax Act, 1961
Facts of the Case
Assessee
Status & Salary Structure: The Assessee (NHK Japan
Broadcasting Corporation) is a foreign government company operating in
India. It paid its Indian employees a local sal...
Commissioner of Income Tax v. M/S D. D. Sales Corporation: Limitation for Block Assessment under Section 158BC read with Section 158BE of the Income Tax Act, 1961
Facts
of the CaseThe Revenue (Commissioner of Income
Tax) preferred an appeal against the order passed by the Income Tax Appellate
Tribunal (ITAT) dated 06.10.1994 in IT (SS) No. 278/Del./1997. The assessment
in ques...
Shri. A.S. Chhachhi Vs. Commissioner of Income Tax: Sequence of Computing Long-Term Capital Gains Deductions Under Section 48(2) Vis-à-Vis Exemptions Under Sections 53 and 54 of Income Tax Act, 1961
FACTS OF THE CASE
Asset
& Transaction: During the financial period relevant to
the assessment year 1989-90, the Assessee (Shri. A.S. Chhachhi) owned a
residential house property situated at Jorbag...