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Principal Commissioner of Income Tax (Central)-1 vs Manoj Hora | Delhi High Court | Penalty under Section 140A(3) and Section 221(1) of the Income Tax Act, 1961
Facts of the
CaseThe Revenue preferred two appeals before the Delhi
High Court against the common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Year 2009-10. The ITAT had set aside the...
Principal Commissioner of Income Tax (Central)-1 vs Sahara India Financial Corporation Ltd. | Delhi High Court | Revenue Appeals under Section 260A of the Income Tax Act Dismissed Against ITAT Order on Cross-Objections
Facts of the CaseThe Revenue preferred multiple appeals before the Delhi High
Court under Section 260A of the Income Tax Act, 1961 challenging the order
dated 13 December 2016 passed by the Income Tax Appellate Tribuna...
Commissioner of Income Tax (International Taxation)-2 vs Net App B.V. | Delhi High Court on Taxability of Software Subscription Receipts as Royalty under Section 9(1)(vii) and Interest Liability under Section 234B
Facts of the CaseThe assessee, Net App B.V., earned income from
sale of software and subscription services for Assessment Years 2008-09 and
2010-11. The Revenue treated these receipts as royalty income taxable in India...
Director of Income Tax vs. Mitsui & Co. Ltd. (Delhi High Court) – Liaison Office, Permanent Establishment (PE) under India-Japan DTAA and Taxability of Business Income under Sections 9(1), 44BBB & 260A of the Income Tax Act, 1961
Facts of the Case
Mitsui
& Co. Ltd., a Japanese company, was a non-resident entity having its
headquarters in Japan.
The
Assessee had undertaken two projects in India:
Anpara
...
Director of Income Tax vs Mitsui & Co. Ltd. | Delhi High Court on Permanent Establishment under India-Japan DTAA, Taxability of Liaison Office & Section 44BBB of Income Tax Act
Facts of the CaseMitsui & Co. Ltd., a non-resident company incorporated in
Japan, had established a Liaison Office (LO) in India with RBI approval. The
company was executing two power-related projects in Indi...
Commissioner of Income Tax (International Taxation)-2 vs Net App B.V. – Taxability of Software Subscription Receipts as Royalty under Section 9(1)(vi) of the Income Tax Act read with Article 12 of India-Netherlands DTAA | Section 234B Interest Liability
Facts of the CaseThe present matter arose from two appeals filed by
the Revenue before the Delhi High Court against the order of the Income Tax
Appellate Tribunal (ITAT) concerning Assessment Years 2008-09 and 20...
Principal Commissioner of Income Tax–7 vs. Bikram Singh | Delhi High Court | Section 68 of the Income-tax Act, 1961 | Unexplained Cash Credits, Identity, Creditworthiness & Genuineness of Loan Transactions
Facts of the CaseThe assessee filed his income tax return for Assessment Year
2011–12 declaring income of ₹80,45,590.During assessment proceedings, the Assessing Officer noticed
unsecured loans/advances aggregating...
Pr. Commissioner of Income Tax-06 vs Modi Apollo International Group (P) Ltd. | Delhi High Court on Section 195 TDS, Fee for Technical Services (FTS) & Royalty Payment under Income Tax Act
Facts of the
CaseThe Revenue preferred appeals against the common
order passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2007-08 and 2009-10.The assessee had made payments to Apollo
Internation...
Pr. Commissioner of Income Tax-06 v. Modi Apollo International Group (P) Ltd. | Delhi High Court | Section 195 TDS on Foreign Payments and Royalty Expenditure under the Income Tax Act, 1961
Facts of the
CaseThe Revenue filed two appeals before the Delhi High
Court against a common order passed by the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2007-08 and 2009-10. The dispute arose o...
Pr. Commissioner of Income Tax-16 vs Jagat Talkies Distributors | Non-Supply of Reasons Recorded under Section 148 Invalidates Reassessment Proceedings | Delhi High Court
Facts of the CaseThe assessee, Jagat Talkies Distributors, was engaged in the
business of film exhibition and also earned rental income from letting out
property. For Assessment Years 1999-2000 to 2004-2005, the assess...