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Reassessment under Section 148A Cannot Proceed on Unverified Shipping Bill Data and PAN Confusion; Matter Remanded for Fresh Consideration: Umesh Chandra Sharma vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, Umesh Chandra Sharma, an individual
assessee, filed a writ petition challenging a notice dated 06.03.2023 issued
under Section 148A(b), an order dated 21.03.2023 passed under Section 1...
Entertainment Tax Subsidy Retained by Multiplex Operators Is Capital Receipt; Purpose Test Applied and Issue Covered by Supreme Court Precedent: PCIT-Central-1 vs. PVR Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed a batch of four appeals under
Section 260A of the Income-tax Act challenging a common order dated 23.10.2024
passed by the Income Tax Appellate Tribunal for Assessment Years 2008-09,...
Different Floors of Same Property Constitute One Residential House for Section 54F; Reopening Beyond Four Years Invalid Without Failure of Disclosure: PCIT-Central-1 vs. Lata Goel (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A
against the ITAT’s order dated 25.09.2024 for Assessment Year 2011-12. The
assessee, Lata Goel, filed her return declaring income of ₹70,87,301 and
...
Block Period under Section 153C to Be Reckoned from Date of Satisfaction Note; AY Falling Outside Ten-Year Block Cannot Be Reopened: PCIT-Central-1 vs. Amol Awasthi (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 13.09.2024 passed by the Income
Tax Appellate Tribunal in ITA No. 1343/Del/2024 for Assessment Year 201...
Penalty under Section 271(1)(c) Unsustainable Where Notice Does Not Specify Charge and Issue Is Debatable; No Substantial Question of Law: PCIT-7 vs. Quippo Telecom Infrastructure Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 06.03.2020 passed by the Income
Tax Appellate Tribunal in respect of Assessment Year 2010-11, whereby t...
Commission Income and Subscription Fees from Sale of Journals Not Taxable as Fees for Technical Services; Issue Covered by Binding Precedents: CIT (International Taxation-3) vs. Springer Nature Customer Service Centre GmbH (Delhi HC)
Facts of the
CaseThe Revenue filed appeals under Section 260A of the
Income-tax Act challenging a common order dated 05.07.2024 passed by the Income
Tax Appellate Tribunal for Assessment Years 2020-21 and 2021-22. The...
Centralised Marketing and Reservation Support Services Not Taxable as Royalty or Fees for Included Services; Issue Covered by Binding Precedents: CIT-IT-3 vs. Six Continents Hotels Inc. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 09.05.2024 passed by the Income
Tax Appellate Tribunal in favour of Six Continents Hotels Inc. for Asse...
Reassessment Proceedings Barred Post CIRP Approval; Clean Slate Doctrine Applies to Income Tax Dues Not Provided in Resolution Plan: Surya Manufacturing Pvt. Ltd. vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Surya Manufacturing Private
Limited, challenged an order dated 10.04.2024 passed under Section 148A(d) of
the Income-tax Act for Assessment Year 2017-18, holding it to be a fit case fo...
Writ Not Entertained Where Effective Appellate Remedy Exists; Jurisdiction under Section 127 Found Valid, Liberty Granted to Pursue Statutory Appeal: Supershine Laundry Systems Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the
CaseThe petitioner, Supershine Laundry Systems Private
Limited, filed writ petitions challenging reassessment orders dated 20.03.2025
passed under Section 147 of the Income-tax Act for the relevant assess...
Section 148 Notice Issued Beyond Permissible Period After Ashish Agarwal Regime Held Time-Barred; Reassessment Quashed: Saroj Mehndi vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, Saroj Mehndi, challenged a notice
dated 11.07.2022 issued under Section 148 of the Income-tax Act for Assessment
Year 2014-15 on the ground that it was barred by limitation. An earlier...