Commissioner of Income Tax vs International Tractors Ltd. – Delhi High Court on Deduction under Section 80-IA, Reassessment under Sections 147/148, Revision under Section 263 & Disallowance under Section 40(a)(i) of the Income-tax Act, 1961

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06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 8
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Facts of the CaseThe assessee, International Tractors Ltd., was engaged in the business of manufacturing and trading agricultural tractors, tractor parts, and components. The company commenced production in Financial ...

TDS on Airport Lounge Royalty / Licence Fee – Whether Payment to Airports Authority of India Constitutes ‘Rent’ under Section 194-I of the Income Tax Act, 1961 | Penalty u/s 271C and Interest u/s 201(1A)

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 9
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 Facts of the CaseThe assessee, I.T.C. Limited, was awarded a contract by the Airports Authority of India (AAI) to operate an Executive Lounge at Indira Gandhi International Airport, New Delhi, through a competit...

Canyon Financial Services Ltd. vs Income Tax Officer | Delhi High Court on Validity of Section 153C Proceedings and “Belongs To” Test under Income Tax Act, 1961

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 10
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Facts of the CaseThe petitioner, Canyon Financial Services Ltd., challenged the legality of satisfaction notes dated 13 March 2014 and 19 March 2014 issued by the Assessing Officers for initiating proceedings under Se...

Delhi High Court | Section 80-IA Deduction to Small Scale Industrial Undertakings (SSI) – Eligibility in Initial Assessment Year vs Subsequent Years | Reassessment u/s 147, Revision u/s 263 & Disallowance u/s 40(a)(i)

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 11
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Facts of the CaseThe assessee, International Tractors Ltd., was incorporated in 1995 and engaged in manufacturing and trading agricultural tractors, tractor parts, and components. Production commenced during Financial ...

Canyon Financial Services Ltd. vs Income Tax Officer (Delhi High Court) – Validity of Proceedings under Section 153C of the Income Tax Act, 1961 | Interpretation of “Belongs To” vs “Pertains To” in Search Assessments

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 10
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 Facts of the CaseThe Income Tax Department conducted search and seizure operations in the Dalmia Group cases in January 2012. During the search, documents were recovered from the possession of Dalmia Equities Pv...

Commissioner of Income Tax vs I.T.C. LimitedWhether Royalty Paid for Operating Executive Lounge at Airport Constitutes ‘Rent’ Liable for TDS under Section 194-I of the Income Tax Act, 1961 | Delhi High Court

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 11
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Facts of the CaseThe assessee, I.T.C. Limited, was awarded a contract by the Airports Authority of India for running an Executive Lounge at the International Terminal of IGI Airport after a competitive bidding process...

Commissioner of Income Tax vs. International Tractors Ltd. Delhi High Court | ITA Nos. 1082/2005, 690/2008, 225/2009, 1189/2009 & 251/2010 | Judgment dated 20 July 2017 Section 80-IA, Section 147, Section 148, Section 263 & Section 40(a)(i) of the Income-tax Act, 1961 – Deduction to Small Scale Industrial Undertaking (SSI), Reassessment, Revisionary Jurisdiction and TDS on Reimbursement of Expenses

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 10
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Facts of the CaseThe assessee, International Tractors Ltd., was incorporated in 1995 and engaged in manufacturing and trading agricultural tractors and tractor parts. It commenced production in Financial Year 1997-98 ...

Canyon Financial Services Ltd. vs Income Tax Officer (Delhi High Court) – Scope of Section 153C of the Income Tax Act, 1961 | Requirement of “Belongs To” for Valid Satisfaction Note in Search Assessment Proceedings

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 11
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 Facts of the CaseThe petitioner, Canyon Financial Services Ltd., challenged satisfaction notes dated 13 March 2014 and 19 March 2014 issued by the Assessing Officers for initiating proceedings under Section 153C...

Delhi High Court | Sections 194-I, 201(1), 201(1A), 271C & 273B of the Income-tax Act, 1961 | TDS on Royalty vs Rent for Airport Lounge Operations | Whether Royalty Paid to AAI for Operating Executive Lounge Constitutes “Rent” Liable for TDS Deduction

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 10
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Facts of the CaseThe Revenue preferred multiple appeals before the Delhi High Court under Section 260A of the Income-tax Act against the order of the Income Tax Appellate Tribunal (ITAT). The dispute arose from payment...

Commissioner of Income Tax vs International Tractors Ltd. | Section 80-IA Deduction for Small Scale Industrial Undertaking, Reassessment under Sections 147/148, Revision under Section 263 & Disallowance under Section 40(a)(i) | Delhi High Court

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My Tax Expert
06/05/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 11
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Facts of the CaseInternational Tractors Ltd. was incorporated in 1995 and commenced manufacturing agricultural tractors and tractor parts in Financial Year 1997-98. The assessee claimed deduction under Section 80-IA as...