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Cloud Computing Receipts Not Taxable as Royalty or FTS in Absence of PE; ITAT Order Upheld: CIT (International Taxation)-1 vs. Amazon Web Services, Inc. (Delhi HC)
Facts of the CaseThe respondent, Amazon Web Services, Inc. (AWS),
is a company incorporated in the United States of America and a tax resident of
the USA. AWS provides standardised and automated cloud computing service...
Section 148 Notice Quashed as Time-Barred Where AY Fell Outside Ten-Year Block Computed under Section 153C Principles: Sunil Kumar Dhaiya vs. ACIT, Central Circle-29 (Delhi HC)
Facts of the CaseThe petitioner, Sunil Kumar Dhaiya, challenged a
notice dated 31.08.2024 issued under Section 148 of the Income-tax Act seeking
to reopen the assessment for Assessment Year 2014-15. The notice was issu...
Unsecured Loan from Director Explained; Section 68 Addition Unsustainable as “Source of Source” Requirement Not Applicable Prior to Finance Act 2022: Sheela Overseas Pvt. Ltd. vs. PCIT (Delhi HC)
Facts of the CaseThe assessee, Sheela Overseas Private Limited, is
engaged in the business of readymade garments and leather goods. For Assessment
Year 2015-16, it filed its return of income on 29.09.2015 declaring a t...
Benefit of Section 115BAA Denied Where Option Not Exercised in Return; CBDT Circular on Form 10-IC Does Not Cure Substantive Lapse: Sarla Holdings Pvt. Ltd. vs. PCIT (Delhi HC)
Facts of the CaseThe petitioner, Sarla Holdings Private Limited,
filed its return of income for Assessment Year 2020-21 on 13.02.2021 within the
extended due date under Section 139(1), declaring total income of ₹60,9...
Reassessment Quashed Where Reopening Based Solely on Penny Stock Investigation Reports Lacked Live Nexus with Assessee: Sanjay Kaul vs. ITO (Delhi HC)
Facts of the CaseThe petitioner, Sanjay Kaul, was an employee of
M/s Laureate Education Pvt. Ltd. and filed his return of income for Assessment
Year 2014-15 declaring taxable income of ₹7,86,72,780 and paid tax of
...
Reassessment for AY 2015-16 Quashed Following Revenue’s Concession in Rajeev Bansal; Notices Issued After 01.04.2021 Not Sustainable: Rajiv Kumar Khandelwal vs. DCIT (Delhi HC)
Facts of the CaseThe petitioner, Rajiv Kumar Khandelwal, is an
individual who filed his return of income for Assessment Year 2015-16 on
30.09.2015 declaring an income of ₹1,36,81,160. The Assessing Officer issued a
...
Reassessment Sustained Where Section 148 Notice Digitally Signed on 31.03.2021 but Issued on 01.04.2021 Attracts Ashish Agarwal Regime: Rajesh Chopra vs. ITO (Delhi HC)
Facts of the CaseThe petitioner, Rajesh Chopra, an individual
resident of New Delhi, filed his return of income for Assessment Year 2013-14
on 08.08.2013 declaring total income of ₹20,59,151. A notice dated 31.03.202...
DCF Valuation Substantiated by Expert Cannot Be Rejected on Generic Disclaimers; Section 56(2)(viib) Addition Set Aside – PCIT-1 vs. A.H. Multisoft Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 05.07.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2016–17. The Tribunal...
Section 153A Assessment Without Incriminating Material Unsustainable; Kabul Chawla and Abhisar Buildwell Applied – PCIT-1 vs. Charvak Trading Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 16.06.2023 passed by the
Income Tax Appellate Tribunal for Assessment Year 2010–11. The Tribunal...
Repair and Maintenance Services of Aircraft Equipment Do Not “Make Available” Technical Knowledge; Receipts Not Taxable as FTS/FIS under India–US DTAA – PCIT (International Taxation) vs. Goodrich Corporation (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 22.08.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2018–19. The Tribunal...