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Marubeni India Pvt. Ltd. & Marubeni Corporation vs. Commissioner of Income Tax: Scope of Income Tax Appellate Tribunal’s (ITAT) Jurisdiction under Section 254(1) in Directing Deductions for Non-Appealed Assessment Years
Facts of the CaseThe appellant, Marubeni India Pvt. Ltd., was incorporated on
May 21, 1996, as a wholly-owned subsidiary of Marubeni Corporation, Japan. Upon
commencing business, the appellant took over the assets, lia...
Commissioner of Income Tax, Delhi II vs. Karl Storz Endoscopy India (P) Ltd.: Clarifying Tax Treatment of Salary Reimbursement vs. Technical Fees
Facts of the CaseThe dispute pertains to the Assessment Year 2001-02 regarding
the tax treatment of a payment amounting to ₹6,59,416 made by the
respondent-assessee, Karl Storz Endoscopy India (P) Ltd., to its parent...
Hacienda Farms Pvt. Ltd. vs. Commissioner of Income Tax: A Critical Analysis of Unexplained Cash Credits under Section 68 of the Income Tax Act, 1961
Facts of the CaseHacienda Farms Pvt. Ltd. (the "Appellant") filed its
income tax return for the Assessment Year 1996-97 with a declared income of
"nil". During the assessment proceedings conducted under Section
143(3)...
Ritz Theatre v. Income Tax Officer | Delhi High Court | Reassessment Proceedings under Sections 147 & 148 Cannot Be Reopened on Issues Already Finally Decided in Earlier Round of Litigation
Facts of the CaseThe assessee, Ritz Theatre, filed returns
for Assessment Years 1990-91, 1991-92, 1992-93, 1995-96 and 1996-97. The
Assessing Officer noticed that the assessee had made disclosures under the
Voluntary ...
Commissioner of Income Tax-IV, New Delhi vs. M/s Dharampal Premchand Ltd.: Leviability of Penalty under Section 271(1)(c) of the Income Tax Act, 1961 on Debatable Issues of Head Office and Unit-Wise Expense Allocations
Facts of the Case
Assessee
Profile and Manufacturing Activities: The
respondent-assessee, M/s Dharampal Premchand Ltd., was actively engaged in
the business of manufacturing flavored chewing tobacco a...
Commissioner of Income Tax vs. Assessee (Name Not Reflected in Order) | Delhi High Court Dismisses Revenue Appeal as Infructuous After Fresh Assessment Accepted Export Sales | ITA No. 971/2009
Facts of the
Case
The Revenue filed an appeal before the Delhi High Court against the
order passed by the Income Tax Appellate Tribunal.
During the proceedings, counsel for the assessee produced a copy of
...
Ritz Theatre vs Income Tax Officer (Delhi High Court) – Service of Notice under Section 148 Once Finally Decided Cannot Be Reopened in Remand Proceedings | Reassessment Proceedings under Sections 147 & 148 of the Income-tax Act
Facts of the
CaseThe assessee, Ritz Theatre, filed income tax
returns for the relevant assessment years. The Assessing Officer noticed that
the assessee had made a declaration under the Voluntary Disclosure of Income
...
Comprehensive Appellate Judgment on the Scope of Revisionary Jurisdiction Under Section 263 of the Income Tax Act, 1961: Commissioner of Income Tax, Delhi-IV v. M/s. International Travel House Ltd. — Judicial Determination on Valid Alternative Accounting Methodologies, Netting Off of Commission Concessions, and the Prohibition Against Roving or Fishing Inquiries by the Commissioner When the Assessing Officer Has Fully Applied His Mind
Facts of
the Case
Assessee
Profile & Original Return: The respondent-assessee,
M/s International Travel House Ltd., operates professionally as a travel
agent and tour operator. For the Asse...
Validity of Reassessment Under Section 147: Signature Hotels (P) Ltd. vs. Income Tax Officer-Ward 8(4) & Anr.
Facts of the Case
The
Petitioner, Signature Hotels (P) Ltd., is a company incorporated on
September 30, 2002.
For
the assessment year 2003-04, the Petitioner filed its return of income on
Mar...
Appellant vs. Respondent-Revenue: Legal Effect of Dismissing a Tax Appeal as "Not Pressed" under Section 260A of the Income Tax Act, 1961 | Delhi High Court
Facts of the CaseThe matter arose out of an income tax appeal docketed as ITA
No. 188/2009 before the Hon’ble High Court of Delhi. The appeal was
preferred by the appellant under the statutory framework of the Income...