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Higher TDS Certificate under Section 197 Quashed After ITAT Set Aside Finding of Permanent Establishment; Revenue Directed to Issue Certificate at 1.5% – GE Energy Parts Inc. vs. ACIT (Delhi High Court)
Facts of the
CaseThe writ petitions were filed by GE Energy Parts
Inc., USA and GE Global Parts and Products GmbH, Switzerland, challenging
certificates issued under Section 197 of the Income-tax Act, 1961 for Assessm...
Virtual Service PE Not Recognised under India-UK DTAA; Section 195 Nil Withholding Certificate Rejection Set Aside: Ernst and Young LLP vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Ernst and Young LLP, filed a writ
petition challenging the certificate and order dated 17.09.2025 passed under
Section 195 of the Income-tax Act, whereby the Assessing Officer directed...
Release of Seized Jewellery, Bullion and Cash Ordered on Deposit of Advance Tax Pending Section 158BC Proceedings – Dhirendra Vir Rastogi vs. ACIT Central Circle-27 (Delhi High Court)
Facts of the
CaseThe petitioner, Dhirendra Vir Rastogi, was one of
the family members forming part of a batch of writ petitions filed before the
Delhi High Court seeking release of movable assets seized during a searc...
TDS Liability under Section 194H Confirmed but Demand Restricted to Interest Only Where Agents Already Paid Tax: CIT Delhi XVII vs. Royal Jordanian Airlines (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal against the order
passed in favour of Royal Jordanian Airlines in relation to Assessment Year
2008-09, concerning non-deduction of tax at source on supplementary commission...
Review Petition Dismissed; No Error Apparent in Direction to Process Returns in Accordance with Law Despite Revenue’s Objections – Bechtel Limited vs. ACIT Circle 1(1)(2), New Delhi (Delhi High Court)
Facts of the
CaseA batch of writ petitions was filed by Bechtel
Limited and Bechtel Power Corporation challenging actions of the Income Tax
Department in relation to processing of income tax returns. The Delhi High
C...
Release of Seized Jewellery, Bullion and Cash Ordered on Deposit of Advance Tax Pending Section 158BC Proceedings – Aryaman Vir vs. ACIT Central Circle-27 (Delhi High Court)
Facts of the
CaseThe petitioner, Aryaman Vir, was one of the family
members forming part of a batch of writ petitions filed before the Delhi High
Court seeking release of movable assets seized during a search conducte...
Reassessment Order under Section 148A Set Aside Where GST Proceedings on Same Transaction Closed Subsequently; Matter Remanded for Fresh Consideration – Vedanta Limited vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Vedanta Limited, filed a writ petition
challenging a notice dated 24.03.2025 issued under Section 148A(1) of the
Income-tax Act, 1961 and the consequent order dated 23.06.2025 passed un...
Jurisdictional AO’s Power to Issue Reassessment Notices Reaffirmed Despite Faceless Scheme; Writ Dismissed Following TKS Builders – Sumanglam Sewa Aivam Education Samiti vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Sumanglam Sewa Aivam Education Samiti, filed
a writ petition challenging notices issued under Section 148 of the Income-tax
Act by the Assistant Commissioner of Income Tax, Central Circ...
Section 264 Revision Against Section 143(1) Intimation Allowed; Refund Directed Despite Pending SLP Argument – Shangri-La International Hotel Management Pte. Ltd. vs. CIT (International Tax) (Delhi HC)
Facts of the CaseThe petitioner, Shangri-La International Hotel Management
Pte. Ltd., filed a writ petition challenging an order dated 26.03.2025 passed
by the Commissioner of Income-Tax (International Tax)-3 under Sec...
Delay of Nine Months in Filing Revised Return Not a Genuine Hardship; Condonation under Section 119(2)(b) Rightly Rejected – Sanjay Khurana vs. Income Tax Department (Delhi HC)
Facts of the CaseThe petitioner, Sanjay Khurana, filed a writ petition
challenging an order dated 05.08.2025 passed by the Principal Commissioner of
Income Tax rejecting his application under Section 119(2)(b) of the I...