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Reassessment Quashed as Time-Barred Where Notice Dispatched After Limitation Despite ITBA Generation Before Cut-Off – Grid Solutions SAS vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Grid Solutions SAS, filed a writ petition
challenging the notice dated 30.03.2025 issued under Section 148A(1) of the Income-tax
Act for Assessment Year 2019–20, the order dated 30.06...
Receipts from Off-the-Shelf Software, Bandwidth and IT Support Services Not Taxable as Royalty or FTS under India–Singapore DTAA; Revenue Appeals Dismissed – CIT (International Taxation) vs. DXC Technology Services Singapore (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of the Income-tax
Act challenging a common order dated 10.10.2023 passed by the Income Tax
Appellate Tribunal in respect of Assessment Years 2011-12 to 2014...
Reassessment for AY 2015–16 Quashed as Time-Barred; TOLA Inapplicable Post Rajeev Bansal – Anju Khosla vs. ITO Ward 15(1) (Delhi HC)
Facts of the CaseThe petitioner, Anju Khosla, challenged a notice dated
26.08.2024 issued under Section 148A(b) of the Income-tax Act for Assessment
Year 2015–16, the order dated 31.08.2024 passed under Section 148A(...
Reassessment Upheld Where No Change of Reasons and Section 148A Procedure Properly Followed Post-2022 Amendment – Amandeep Singh (Guru Kripa Enterprises) vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Amandeep Singh, proprietor of Guru Kripa
Enterprises, filed his return of income for Assessment Year 2021–22 on
14.03.2022 declaring income of ₹8,53,950. On 29.03.2025, the Revenue ...
Jurisdiction of Jurisdictional Assessing Officer Upheld Despite Faceless Scheme; Reassessment Notices Sustained in Delhi – All India Kataria Educational Society vs. ACIT (Delhi HC)
Facts of the CaseA batch of writ petitions, including those filed by All India
Kataria Educational Society and connected assessees, were filed before the
Delhi High Court challenging notices issued under Section 148 of...
Invalid Remand by CIT(A) Set Aside Where Jurisdictional Defect under Section 143(2) Not Adjudicated; Matter Restored to CIT(A) – Akasaki Technology (P) Ltd. vs. PCIT (Delhi HC)
Facts of the CaseThe assessee, Akasaki Technology (P) Ltd., filed its return of
income for Assessment Year 2012–13 on 28.09.2012 declaring total income of
₹48,51,840. The assessment was reopened under Section 147 o...
Delay of 184 Days Condoned and Appeal Restored for Adjudication on Merits: Urmila RCP Projects Private Limited vs. ITO (TDS), Ranchi (ITAT)
Facts of the CaseThe
assessee, Urmila RCP Projects Private Limited, Ranchi, filed an appeal against
the order dated 10.01.2025 passed by the Additional/Joint Commissioner of
Income Tax (Appeals)-1, Delhi for Assessmen...
Matter Restored to CIT (Exemption) for Fresh Adjudication Due to Non-Furnishing of Documents: Swami Vivekanand Seva Trust vs. CIT (Exemption), Patna (ITAT)
Facts of the CaseThe
assessee, Swami Vivekanand Seva Trust, Jamshedpur, filed an appeal against the
order dated 20.09.2024 passed by the Commissioner of Income Tax (Exemption),
Patna for Assessment Year 2024-25. Durin...
Reassessment Quashed for Granting Less Than Statutory Seven Days under Section 148A(b): Sunil Kumar vs. ITO, Ward-3(1), Bokaro (ITAT)
Facts of the CaseThe
assessee, Sunil Kumar, Bokaro, filed an appeal against the order dated
17.01.2025 passed by the Commissioner of Income Tax (Appeals), National
Faceless Appeal Centre, Delhi for Assessment Year 201...
Reassessment Quashed for Non-Supply of Mandatory Approval under Section 151: Smita vs. ITO, Ward-3(4), Chaibasa (ITAT)
Facts of the CaseThe
assessee, Smita, filed her return of income for Assessment Year 2018-19
declaring total income of ₹6,07,870. Subsequently, the Assessing Officer issued
a notice under Section 148 on the allegati...