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PR. Commissioner of Income Tax, Delhi-21 vs Lalit Bagai | Reassessment u/s 147 Invalid on Change of Opinion & Audit Objection – Delhi High Court
Facts of the
CaseThe assessee, Lalit Bagai, filed his return for AY
2006–07 declaring income of ₹1.02 crore. The case was selected for scrutiny and
assessment was completed under Section 143(3), wherein certain di...
Principal Commissioner of Income Tax-9 vs Om Prakash Jakhotia & Anr (2019) – Delhi High Court on Full & True Disclosure under Section 245C and Invalid Retraction of Statement
Facts of the
CaseThe case arose from a search and seizure
operation conducted on 20.01.2012 at the premises of the assessee group
(Jakhotia group) and related entities. During the search:
Cash of ₹35 lakhs a...
Vanita Sanjeev Anand vs Income Tax Officer Ward 45(1) – Reopening of Assessment u/s 147 & 148 Quashed Due to Non-Application of Mind (Delhi High Court)
Facts of the CaseThe petitioner, a regular assessee, filed her income tax
return for AY 2011–12. Subsequently, based on information from the
Investigation Wing regarding loan transactions with a third party (M/s Dugg...
Commissioner of Income Tax, Delhi vs Anoop Jain (Delhi High Court) – Section 69A Income Tax Act | Addition of Unexplained Money Deleted Where Assessee Acted as Conduit
Facts of the
CaseThe case pertains to Assessment Year 1992–93 where
the assessee, a stockbroker and member of the Delhi Stock Exchange, filed a
return declaring income of ₹3,96,960. During scrutiny, the Assessing ...
Gurudwara Sahib Patti Dhaliwal vs Chief Commissioner of Income Tax (Exemptions) (2020) – Delhi High Court | Agricultural Land vs Capital Asset | Section 2(14), 10(37), 119(2)(b) Income Tax Act
Facts of the CaseThe Petitioner, Gurudwara Sahib Patti Dhaliwal, filed
a writ petition challenging the order dated 27.12.2018 passed by the Chief
Commissioner of Income Tax (Exemptions), Delhi, rejecting its applicatio...
M/s McKinsey Knowledge Centre India Pvt. Ltd. vs Pr. Commissioner of Income Tax, Delhi-6 (2019) – Delhi High Court | Review Allowed on Transfer Pricing & Section 92B Issues
Facts of the
Case
The assessee, engaged in IT-enabled services (ITES),
categorized its operations into:
Research & Information Services Division
IT Support Services Division
The disput...
Commissioner of Income Tax (Exemption) vs Association of Third Party Administrators | Delhi High Court | Section 12AA Registration | Charitable Purpose u/s 2(15)
Facts of the CaseThe respondent, Association of Third Party Administrators
(ATPA), applied for registration under Section 12A of the Income Tax Act on
12.12.2005. The application was rejected by the Director of Income ...
Commissioner of Income Tax (International Taxation)-2 vs ZTE Corporation (2019) – Delhi High Court | Software Supply Not Royalty under Indo-China DTAA, Section 9(1)(vi) & Section 234B
Facts of the
CaseThe present appeals were filed by the Revenue against
the respondent-assessee, ZTE Corporation, before the Delhi High Court. The core
issue arose from the tax treatment of payments received by the ass...
Housing and Urban Development Corporation Ltd. vs. Additional Commissioner of Income Tax (Delhi High Court) – Section 260A | Allowability of Salary Provision & Accounting Policy Change
Facts of the CaseThe appellant, a Public Sector Undertaking (HUDCO), filed
its return for AY 2007–08 declaring income, later revised downward. The case
was scrutinized and assessed under Section 143(3).Subsequently, ...
Commissioner of Income Tax (International Taxation)-2 vs ZTE Corporation | Delhi High Court | Software Payments Not Royalty under Indo-China DTAA | Section 9(1)(vi) & Section 234B Analysis
Facts of the
CaseThe present appeals (ITA 763/2019, 769/2019, and
771/2019) were filed by the Revenue before the Delhi High Court against ZTE
Corporation. The dispute revolved around the taxability of payments receive...