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Addition under Section 68 Unsustainable Where Assessee Did Not Transfer Property and Alleged Undervaluation Arose Only from Share Transfers Between Shareholders; ITAT Remand Set Aside – Snerea Properties Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe assessee,
Snerea Properties Pvt. Ltd., filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 19.01.2025 passed by the
Income Tax Appellate Tribunal in ITA No....
Addition under Section 68 Not Sustainable Where No Transfer of Property by Assessee and Transaction Involves Share Transfer Between Shareholders; ITAT Remand Set Aside – Shrey Properties Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe assessee,
Shrey Properties Pvt. Ltd., filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 19.01.2025 passed by the
Income Tax Appellate Tribunal in ITA No. ...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year; Search-Based Reopening Quashed – Shashank Gupta vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Shashank Gupta, filed a writ petition challenging the notice dated 25.03.2025
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2014–15 and the proceedings in...
Section 148 Notice for AY 2016–17 Time-Barred under First Proviso to Section 149; Limitation Not Extended by Earlier Litigation – Sanjay Bansal vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Sanjay Bansal, filed a writ petition challenging the notice dated 15.04.2024
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2016–17. The impugned notice wa...
Reassessment Initiated During Pending Scrutiny Assessment Is Without Jurisdiction; Parallel Proceedings under Sections 147 and 143(3) Impermissible – Salesforce.com Singapore Pte. Ltd. vs. DCIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Salesforce.com Singapore Pte. Ltd., filed a writ petition challenging the
assessment order dated 21.01.2025 passed under Section 147 read with Section
144C(13) of the Income-tax Act, ...
Reassessment Notice for AY 2015–16 Issued After 1 April 2021 Is Time-Barred; Proceedings Quashed Following Rajeev Bansal – Roopa Goyal vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Roopa Goyal, filed a writ petition challenging the initial notice dated
23.06.2021 issued under Section 148 of the Income-tax Act, 1961, subsequent
notices dated 31.05.2022, the order...
Reassessment Notices for AY 2015–16 Issued After 1 April 2021 Liable to Be Dropped in View of Revenue Concession in Rajeev Bansal; Section 148 Proceedings Quashed – Rangoli Infocom Pvt. Ltd. vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Rangoli Infocom Private Limited, filed a writ petition challenging the notice
dated 27.04.2021 issued under Section 148 of the Income-tax Act, 1961, the
notice dated 27.05.2022 issued...
Reassessment for AY 2013–14 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO to Examine Limitation Afresh – Rajesh Agarwal vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Rajesh Agarwal, filed a writ petition challenging the initial notice dated
17.06.2021 issued under Section 148 of the Income-tax Act, 1961, subsequent
notices dated 24.05.2022, the or...
Sanction for Prosecution under Section 279 Validly Granted by Principal Director; Criminal Proceedings under Sections 276C(1) and 277A Not Premature – Raj Kumar Kedia vs. Income Tax Office (Delhi High Court)
Facts of the
CaseThe petitioner,
Raj Kumar Kedia, filed two petitions under Section 482 of the Code of Criminal
Procedure read with Article 227 of the Constitution seeking quashing of
Criminal Complaint Nos. 516654/2...
Addition under Section 68 Not Sustainable Where Identity, Creditworthiness and Genuineness of Share Applicants Established; No Requirement to Prove Source of Source for AY 2012–13 – Revenue Appeal Dismissed – PCIT-1 vs. Central Plastics Pvt. Ltd. (Delhi High Court)
Facts of the
CaseThe Revenue filed
an appeal under Section 260A of the Income-tax Act, 1961 challenging the order
dated 31.05.2023 passed by the Income Tax Appellate Tribunal in ITA No.
65/Del/2017 for Assessment Yea...