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Toby Consultants (P) Ltd. vs Commissioner of Income Tax – Addition under Section 68 for Unexplained Cash Credits and Failure to Prove Genuineness of Loan Transactions Applying the Test of Human Probabilities | Delhi High Court
Facts of the Case
The
assessee company was engaged in the business of investment in securities.
For
Assessment Year 2001-02, the assessee disclosed unsecured loans amounting
to:
Rs.
2,6...
Commissioner of Income Tax vs. Assessee (Appellant): A Judicial Analysis on the Scope of Section 263 of the Income Tax Act, 1961
Facts of the CaseFor the Assessment Year 2001-02, an assessment order was
initially finalized by the Assessing Officer (AO) on February 26, 2004, under
Section 143(2) of the Income Tax Act, 1961. Following a review of ...
Commissioner of Income-Tax, Central-III vs Paltiputra International Trading Ltd. – Validity of Search Warrants, Limitation for Block Assessment and Authority under Sections 132 & 158BE of the Income-tax Act, 1961 | Delhi High Court
Facts of the Case
Search
and seizure operations were conducted against a group of companies
connected with the alleged Urea Scam investigations.
Warrants
of authorization were issued for search of l...
M/s Havells India Ltd. vs Deputy Commissioner of Income Tax – Validity of Special Audit under Section 142(2A) of the Income-tax Act, 1961 and Requirement of a Speaking Order | Delhi High Court
Facts of the Case
A
show cause notice dated 30 September 2009 was issued to the petitioner
proposing a Special Audit under Section 142(2A).
The
notice contained detailed allegations and observ...
Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009:DHC:8824-DB): A Comprehensive Legal Analysis of TDS Obligations on Payments for Foreign Software Services under Section 195(2) of the Income Tax Act, 1961
Facts of the CaseThe respondent, Sahara Airlines Ltd., engaged in commercial
arrangements with two international entities: M/s. Amadeus Marketing, a Spanish
corporation, and M/s. Galileo International, an American corp...
Ashok Arora v. Commissioner of Income Tax, Circle XIII, New Delhi – Validity of Reassessment Proceedings under Sections 147/148 and Best Judgment Assessment under Section 144 of the Income Tax Act, 1961
Facts of the Case
The Income Tax Department issued a notice dated 27 February 2009
under Section 148 of the Income Tax Act, 1961 seeking to reopen the
petitioner’s assessment for Assessment Year 2002-03.
...
Commissioner of Income-Tax, Central-III vs Shilpi Securities Pvt. Ltd. & Connected Assessees – Validity of Search Warrants, Limitation of Block Assessment and Powers under Sections 132 & 158BE of the Income-tax Act | Delhi High Court
Facts of the Case
Search
and seizure operations were conducted against a group of assessees
connected with the same business group.
Search
warrants were issued authorizing searches of bank accounts,...
Comprehensive Legal Analysis: Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009) – Delhi High Court Judgment on TDS Liability for International Software Usage Payments and DTAA Interpretations under Article 13(2)(ii) of DTAA
Facts of the CaseThe respondent, Sahara Airlines Ltd., entered into
commercial arrangements with two distinct international entities to facilitate
their business operations. These entities included M/s. Amadeus Marketi...
Commissioner of Income Tax vs Goetze (India) Ltd. (2010) 2010:DHC:317-DB | Reassessment under Sections 147/148 Invalid Due to Mere Change of Opinion After Full Disclosure of Material Fact
Facts of the Case
The assessee, Goetze (India) Ltd., had claimed prior period
expenses amounting to ₹75,96,534.
During the original assessment proceedings under Section 143(3),
the Assessing Officer re...
Commissioner of Income Tax vs Honda Siel Cars India Ltd. – Allowability of Advertisement & Publicity Expenditure and Royalty Payments as Revenue Expenditure under Section 37(1) of the Income-tax Act, 1961 | Delhi High Court
Facts of the Case
The
assessee incurred expenditure towards advertisement and publicity for
promoting its business activities.
The
assessee also paid royalty to its Japanese collaborator under the t...