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Commissioner of Income Tax v. Assessee (ITA No. 1437/2006 & ITA No. 21/2009) – Reassessment Proceedings Invalid Without Mandatory Approval of Joint Commissioner under Section 151(1)(ii) of the Income-tax Act | Delhi High Court
Facts of the
Case
Reassessment proceedings were initiated under the provisions of the
Income-tax Act.
Prior sanction as contemplated under Section 151(1)(ii) was
required before issuance of the reassessm...
CIT vs. Mas Services Private Limited (Alternatively framed based on parties: Commissioner of Income Tax vs. [Assessee]) | Revenue vs. Capital Expenditure: Payment for Short-Term Use of Goodwill under Section 37(1) of the Income Tax Act
Facts
of the CaseThe assessee entered into a specific
business agreement with M/s. Mas Services Private Limited. Under the terms of
this agreement, M/s. Mas Services Private Limited permitted the assessee to
utilize ...
Commissioner of Income Tax vs. Assessee Company under Section 80-IA of the Income-tax Act, 1961 [Delhi High Court | ITA Nos. 17/2009 & 18/2009 | Judgment dated 18 November 2009]
Facts of the CaseThe Revenue filed appeals before the Delhi High
Court challenging the order of the Income Tax Appellate Tribunal (ITAT). The
Tribunal had directed the Assessing Officer to allow deduction under Section...
Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others: Applicability of TDS Under Section 194H on Supplementary Commission and Concessional Tickets to Travel Agents
Facts of the Case
The
Revenue preferred a batch of appeals against various foreign and domestic
airlines (including Singapore Airlines, KLM Royal Dutch Airlines, British
Airways, Air France, and Air I...
Commissioner of Income Tax vs. Singapore Airlines Ltd & Ors. | Applicability of TDS on Supplementary Commission to Travel Agents under Section 194H of Income Tax Act
Facts of the CaseThe Income Tax Department conducted a survey under
Section 133A on various international and domestic airlines (including
Singapore Airlines, KLM Royal Dutch Airlines, Air France, British Airways, and
...
Delhi High Court Dismisses Revenue’s Section 260A Appeal Due to Tax Effect Below ₹4 Lakhs: CBDT Monetary Limit Reaffirmed | ITA No. 759/2009
Facts
of the CaseThe Appellant (Revenue/Income Tax
Department), represented by senior counsel, preferred an appeal (ITA No.
759/2009) before the Hon’ble High Court of Delhi against the order of the
Income Tax Appel...
Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others: Applicability of TDS under Section 194H on Supplementary Commission and Concessional Tickets
Facts of the Case
Parties
Involved: The Revenue (represented by the
Commissioner of Income Tax, New Delhi) filed a batch of appeals against
various international and domestic airlines, including Singa...
Commissioner of Income Tax vs. Garment Export Assessee – Whether Fabrication Charges Can Be Disallowed Entirely When Export of Garments is Established and Fabrication Activity is Undisputed under Section 37(1) of the Income Tax Act, 1961 | ITA No. 1082/2009
Facts of the
Case
The assessee claimed fabrication charges amounting to Rs.
54,86,500/- in relation to the manufacture of ready-made garments.
The Assessing Officer disallowed the entire expenditure on the
...
Commissioner of Income Tax vs. Singapore Airlines Ltd. (And Connected Appeals, Including CIT vs. Lufthansa German Airlines) – High Court of Delhi | Legal Interpretation of Section 194H of the Income Tax Act, 1961: Mandatory Tax Deduction at Source (TDS) on Travel Agents' Supplementary Commission vs. Taxability of Concessional Airline Tickets as Trade Discounts under Section 201
Facts of the Case
The
Revenue preferred a batch of appeals against various foreign and domestic
airlines (including Singapore Airlines, KLM Royal Dutch Airlines, British
Airways, Air France, and Air I...
Commissioner of Income Tax vs Singapore Airlines Ltd. & Others (2009:DHC:1331-DB): Applicability of Section 194H on Supplementary Commission of Travel Agents and Treatment of Concessional Airline Tickets under Income Tax Act, 1961.
Facts of the Case
The
assessee-airlines provide blank neutral tickets to authorized travel
agents. The billing, accounting, and settlement data are periodically
processed through the Billing Settlemen...