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Transfer Pricing Royalty Benchmarking under CUP Sustained; Selection of Comparables a Pure Question of Fact – PCIT-7 vs. Tupperware India Pvt. Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed two appeals under Section 260A of the
Income-tax Act, 1961 challenging a common order dated 12.03.2025 passed by the
Income Tax Appellate Tribunal in ITA No. 9727/Del/2019 for Assessm...
No Addition under Section 153A for Unabated Years Without Incriminating Material; Revenue Appeal Dismissed Following Abhisar Buildwell – PCIT-1 vs. Mirage Homes Pvt. Ltd. (Delhi HC)
Facts of the CaseA search under Section 132 of the Income-tax Act, 1961 was
conducted in the case of the assessee group. For Assessment Year 2004–05, the
Assessing Officer completed assessment under Section 153A maki...
Penalty under Section 271(1)(c) Invalid for Defective Notice Not Specifying Charge; Revenue Appeal Dismissed on Merits and Delay – PCIT-Central-1 vs. Chetan Gupta (Delhi HC)
Facts of the CaseThe Revenue filed an appeal under Section 260A challenging the
order dated 28.06.2022 passed by the Income Tax Appellate Tribunal in ITA No.
896/Del/2015, whereby the Tribunal allowed the assessee’s ...
Section 153C Proceedings for AY 2013–14 Held Time-Barred; Six-Year Period to Be Reckoned from Date of Handing Over of Seized Material – PCIT (Central) Gurugram vs. Deepak Kumar Aggarwal (Delhi HC)
Facts of the CaseA search and seizure operation under Section 132 of the
Income-tax Act, 1961 was conducted on 02.11.2017 at the residential premises of
Prahlad Kumar Aggarwal in the case of the Rajesh Jain Group. Duri...
Low Tax Effect Objection Rejected Where Case Falls Under ‘Accommodation Entry’ Exception; Review Petition Dismissed – PCIT-1 vs. Agroha Fincap Ltd. (Delhi HC)
Facts of the CaseThe Revenue filed ITA No. 60/2024 against Agroha Fincap Ltd.,
which was decided by the Delhi High Court on 06.10.2025. Thereafter, the
assessee filed Review Petition No. 567/2025 seeking review of the ...
Reassessment Notice for AY 2015–16 Quashed as Time-Barred under Section 149; TOLA Inapplicable – Ms. Swati Varmani vs. ITO Ward 30(1) (Delhi HC)
Facts of the CaseThe petitioner, Ms. Swati Varmani, filed a writ petition
challenging notice dated 25.05.2022 issued under Section 148A(b), order dated
26.07.2022 passed under Section 148A(d), and notice dated 26.07.20...
Condonation of Delay under Section 119(2)(b) Denied Where No Genuine Hardship Shown; Ignorance of Law Not a Ground – Manjit Singh Dhaliwal vs. CIT (International Taxation) (Delhi HC)
Facts of the CaseThe petitioner, Manjit Singh Dhaliwal, a Canadian citizen and
non-resident for Assessment Year 2020–21, sought condonation of delay in filing
his income tax return for the said year under Section 119...
Reassessment Notice for AY 2014–15 Set Aside for Fresh Examination of Surviving Limitation Period in Light of Rajeev Bansal Judgment – Filatex India Ltd. vs. ACIT (Delhi High Court)
Facts
of the CaseThe
petitioner, Filatex India Ltd., challenged the notice dated 08.06.2021 issued
under the erstwhile Section 148 of the Income Tax Act, 1961, subsequently
deemed to be a notice under Section 148A(b)...
Delay of 16 Days in Filing Form 10B Directed to be Condoned under Section 119(2)(b); Rejection Order Set Aside: Delhi Maharashtriya Educational and Cultural Society vs. CIT (Exemptions) (Delhi HC)
Facts
of the CaseThe
petitioner, Delhi Maharashtriya Educational and Cultural Society, is a society
registered under the Societies Registration Act, 1860 and engaged in charitable
and welfare activities. For Assessme...
Reassessment Orders Set Aside for Non-Speaking Section 148A(3) Decisions; AO Directed to Pass Reasoned Orders After Supplying Material – MakeMyTrip India Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the CaseThe petitioner, MakeMyTrip India Private Limited, filed two
writ petitions challenging reassessment proceedings for Assessment Years
2020-21 and 2021-22. The challenge was directed against show cause n...