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Reassessment Based Solely on Subsequent Survey Unsustainable; PE Existence Must Be Examined Year-wise – GE Grid (Switzerland) GmbH vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, GE Grid (Switzerland) GmbH, a
company incorporated in Switzerland, filed a batch of writ petitions
challenging reassessment proceedings initiated under Section 148 of the
Income-tax A...
Freight Logistic Support Services Do Not Constitute FTS/FIS Absent “Make Available”; DTAA Protection Affirmed – CIT (International Tax-1) vs. Expeditors International of Washington Inc. (Delhi HC)
Facts of the
CaseThe Revenue filed a batch of appeals under Section
260A of the Income-tax Act, 1961 for multiple assessment years against common
orders of the Income Tax Appellate Tribunal in favour of Expeditors
In...
MAP Framework Cannot Be Applied to Non-Covered Transactions; ALP Must Be Determined Under Section 92C – AON Consulting Pvt. Ltd. vs. PCIT-1 (Delhi HC)
Facts of the
CaseThe appellant, AON Consulting Pvt. Ltd. (successor
entity of Hewitt Associates (India) Pvt. Ltd.), filed an appeal under Section
260A of the Income-tax Act, 1961 challenging the order dated 20.12.2023...
Reassessment Proceedings Set Aside for Granting Less Than Statutory Time under Section 148A(b); Mandatory Opportunity of Hearing Reaffirmed – Anuj Ghuliani vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, Anuj Ghuliani, filed a writ
petition under Articles 226 and 227 of the Constitution of India seeking
quashing of the notice dated 21.08.2024 issued under Section 148A(b) of the
Income...
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...