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PR. Commissioner of Income Tax-7 vs Sumitomo Corporation India Pvt. Ltd. | Delhi High Court | AY 2015-16 & 2016-17 | No Substantial Question of Law
Facts of the Case
The
Revenue filed appeals before the High Court against the order of the ITAT
dated 24.11.2021.
The
appeals related to AY 2015-16 and AY 2016-17.
There
was a delay of 214...
PR. Commissioner of Income Tax (Central)-2 vs Anuj Bansal (2023) – Delhi High Court | Invalid Approval u/s 153D due to Non-Application of Mind
Facts of the CaseThe respondent/assessee filed a return declaring income of
₹87,20,580. The Assessing Officer (AO), while framing assessment under Sections
153A read with 143(3), made significant additions including:...
Principal Commissioner of Income Tax, Delhi-4 vs Nestle India Ltd (Delhi High Court) – No Substantial Question of Law on Disallowance, Section 14A & Depreciation Issues
Facts of the CaseThe appeal was filed by the Revenue challenging the order of
the Income Tax Appellate Tribunal (ITAT) dated 31.07.2020 concerning Assessment
Year 2011–12.The Assessing Officer (AO) had made mul...
Jyoti Narang vs Income Tax Officer (Delhi High Court) – Breach of Natural Justice due to Incorrect Email Service of Show Cause Notice under Income Tax Proceedings
Facts of the CaseThe present writ petition was filed before the Delhi High
Court by the petitioner, Jyoti Narang, challenging the assessment order dated
23.05.2023 passed by the Income Tax Department.The petitioner con...
Vodafone Roaming Services SARL vs Assistant Commissioner of Income Tax (Delhi High Court, 2023) – Reassessment & Natural Justice under Sections 148A, 144C IT Act
Facts of the Case
The
petitioner, Vodafone Roaming Services SARL, is a tax resident of
Luxembourg.
The
Revenue alleged that the petitioner failed to file a return for AY
2014–15.
I...
Siemens Industry Software NV vs Assistant Commissioner of Income Tax (International Tax), Circle 3(1)(2), New Delhi & Anr. | Delhi High Court | AY 2019-20 | Reassessment due to Incorrect TDS Entry Set Aside
Facts of the CaseThe present writ petition pertains to Assessment Year (AY)
2019–20. The petitioner, Siemens Industry Software NV, was subjected
to reassessment proceedings triggered due to an error in the Tax Deduct...
Sukhdeep Singh Chadha vs Assessment Unit, Income Tax Department (Delhi High Court, 2023) – Violation of Natural Justice under Sections 143(3) & 144B of Income Tax Act
Facts of the Case
The
case pertains to Assessment Year (AY) 2021–22.
A
show cause notice dated 07.06.2023 was issued proposing variation in
taxable income.
The
petitioner was given time ...
Principal Commissioner of Income Tax-7 vs Polyplex Corporation Ltd. – Tax Sparing Credit under Indo-Thailand DTAA (Section 90, Income Tax Act, 1961)
Facts of the CaseThe case pertains to Assessment Years 2010–11 to 2013–14,
where the assessee, Polyplex Corporation Ltd., earned dividend income from its
Thai subsidiary. The assessee claimed foreign tax credit amo...
Principal Commissioner of Income Tax–7 vs M/s Polyplex Corporation Ltd (Delhi High Court, 2023) – Tax Sparing Credit under Indo–Thailand DTAA u/s 90(2) of Income Tax Act
FACTS OF THE CASE
The
assessee earned dividend income from its Thai subsidiary.
Thailand
granted tax exemption on such dividend under its domestic law.
The
assessee claimed tax credit in India (...
PR. Commissioner of Income Tax, Central-11 vs DSC Ltd. (Delhi High Court) – Reopening of Assessment u/s 147 Beyond 4 Years Held Invalid in Absence of Failure to Disclose Material Facts
Facts of the CaseThe respondent-assessee, DSC Ltd., filed its return of income
for AY 2006–07 declaring income of ₹54.14 crores. The case was originally
assessed under Section 143(3).Subsequently, a search operatio...