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Srivenkateshwar Tradex Pvt. Ltd. vs Principal Commissioner of Income Tax & Anr. – Reassessment Proceedings Set Aside Due to Violation of Statutory Time Limit under Section 148A(b) of Income Tax Act, 1961
Facts of the CaseThe petitioner, Srivenkateshwar Tradex Private Limited, was
subjected to reassessment proceedings for Assessment Year 2019–20. The
Assessing Officer issued a notice under Section 148A(b) alleging bog...
Heritage Holidays Pvt. Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court, 2023) – Reassessment u/s 148A Upheld; Issues under Sections 50C, 43CA & 2(47)(v) Examined
Facts of the CaseThe petitioner, Heritage Holidays Pvt. Ltd., filed a
writ petition challenging reassessment proceedings initiated for Assessment
Year 2019–20 under the Income Tax Act, 1961.
A
notice dated 15...
Usha Gupta vs Income Tax Officer, Ward-36(1), Delhi & Ors. (Delhi High Court, 2023) – Reassessment Order Set Aside for Violation of Principles of Natural Justice under Sections 147 & 144B of the Income Tax Act
Facts of the CaseThe petitioner challenged an assessment order dated
18.05.2023 passed under Sections 147 read with 144B of the Income Tax Act for
Assessment Year 2013–14. A show cause notice dated 08.05.2023 was iss...
Commissioner of Income Tax (International Taxation)–2 vs M/s CSG International Ltd. | Delhi High Court | Section 9 & DTAA | Software Royalty Issue
Facts of the Case
The
assessee, M/s CSG International Ltd., was incorporated in the United
Kingdom and engaged in software-related services.
For
AY 2003–04, it declared income including fees for ...
PR. Commissioner of Income Tax-7 vs Oriental Bank of Commerce Ltd. (Now Merged with Punjab National Bank Ltd.) – Section 14A, 36(1)(vii) & Banking Taxation Issues | Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against the order dated 04.03.2022 passed by the
Income Tax Appellate Tribunal concerning Assessment Years 2013-14, 2014-15, a...
Nokia Corporation vs Deputy Commissioner of Income Tax Circle 2(2)(2) International Tax & Ors. | Delhi High Court | Refund Verification & Indemnity Bond Mechanism under Income Tax Law
Facts of the Case
The
petitioner claimed a total refund of ₹29.06 crore for AYs 1997–98
to 2002–03.
The
Revenue verified ₹22.46 crore out of the principal amount.
The
verified amou...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA | Delhi High Court | ITA 489/2023 & 490/2023 | AY 2017-18 & 2019-20 | Profit Attribution to PE, Royalty vs Business Income, FAR Analysis
Facts of the Case
The
appeals were filed by the Revenue against a common order of the ITAT
dated 13.09.2022.
The
matter pertained to Assessment Years 2017-18 and 2019-20.
The
dispute invol...
PR. Commissioner of Income Tax (Central-1) vs VE Commercial Vehicles Ltd – Allowability of Bad Debts & Training Expenses under Sections 36(1)(vii), 36(2) & 37 of Income Tax Act
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT) for
Assessment Year 2011–12.Two primary issues arose:
Deduction claimed by the assesse...
Intertek India Private Limited vs Assistant Commissioner of Income Tax, Circle 10(1), New Delhi | Delhi High Court | Rectification Delay & Interest under Section 244A
Facts of the CaseThe petitioner, Intertek India Private Limited, filed a
rectification application dated 25.05.2016 under Section 154 of the Income Tax
Act, 1961. The grievance raised was that the said rectification ap...
PR. Commissioner of Income Tax (Central)-1 vs VE Commercial Vehicles Ltd. – Allowability of Bad Debts Post Demerger under Sections 36(1)(vii) & 36(2) of the Income Tax Act
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court concerning Assessment Year 2010–11. The dispute
arose from an order passed by the Income Tax Appellate Tribunal (ITAT) dated
...