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Commissioner of Income Tax vs. M/s Xerox Modicorp Limited | Validity of Reassessment Proceedings Under Section 147 and Entitlement to Investment Allowance Under Section 32A read with Eleventh Schedule for Xerographic Machine Manufacturers | Delhi High Court Judgment Case Law
FACTS OF THE CASE
Assessee
Business Operations: The Respondent-Assessee, M/s Xerox
Modicorp Limited, was engaged in the manufacturing and commercial
distribution of xerographic machines, toners, devel...
Commissioner of Income Tax vs. M/s Triveni Engineering Works Ltd. (Delhi High Court) – Revision under Section 263 Cannot Be Invoked Against IAC Assessment Orders Prior to 01.10.1984
Facts of the
Case
The dispute related to Assessment Year 1979-80.
The assessment was completed on 27 February 1982 under Section
143(3) by the Inspecting Assistant Commissioner (Assessment), Range-III.
The a...
Commissioner of Income Tax v/s Xerox Modicorp Limited: Legality of Section 147 Reassessment Proceedings Initiated Beyond Four Years to Withdraw Section 32A Investment Allowance and Section 80-I Deductions on Prohibited Eleventh Schedule Office Machines and Photocopiers
Facts of the Case
Business
Profile: The respondent-assessee, M/s. Xerox Modicorp
Limited, was actively engaged in the industrial manufacturing and
commercial distribution of xerographic machines, tone...
Commissioner of Income Tax v. AKS Alloys (P) Ltd. | No Taxability of Interest on Accrual Basis Where Recovery Becomes Uncertain – Application of Real Income Theory | Delhi High Court
Facts of the
CaseFor Assessment Year 2001-02, the assessee company
filed its return declaring income of ₹10,208.During assessment proceedings, the Assessing
Officer observed that the assessee had invested ₹130 lak...
Director of Income Tax vs. SNC Lavalin International Inc. – Taxability of Fees for Included Services under Article 12(4) of India-Canada DTAA | Delhi High Court
Facts of the
CaseSNC Lavalin International Inc., a non-resident
company engaged in infrastructure consultancy, entered into an agreement with
NHAI for infrastructure development projects funded by the World Bank.Under...
Commissioner of Income Tax vs. M/s. Xerox Modicorp Limited | Validity of Reassessment Proceedings Under Section 147 and Eligibility for Investment Allowance Reserve Under Section 32A Over Eleventh Schedule Restrictions on Office Photocopying Apparatus
Facts of the Case
Assessee
Business Operations: The respondent-assessee, M/s. Xerox
Modicorp Limited, is engaged in the primary industrial activities of
manufacturing xerographic machines (office copy...
Director of Income Tax v. Various Assessees (Following Director of Income Tax v. Mitsubishi Corporation) – Section 234B Interest Not Leviable Where Income is Subject to TDS | Delhi High Court
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court raising a common question regarding the charging of interest under
Section 234B of the Income-tax Act, 1961.The controversy arose in case...
Commissioner of Income Tax Delhi-IV vs Dewan Steels Ltd. | Section 43B of the Income Tax Act – Disallowance of Unpaid Interest Payable to IDBI Bank and Nature of Lease Financing Transaction
Facts of the Case
The assessee, Dewan Steels Ltd., had entered into an arrangement
with IDBI Bank relating to plant and machinery.
During assessment proceedings, the Assessing Officer found that an
amoun...
Director of Income Tax vs. M/s SNC Lavalin International Inc. (Delhi High Court) – Taxability of Technical Consultancy Fees under India–Canada DTAA | Interpretation of Article 12(4)(b) – Development and Transfer of Technical Plans/Designs
Facts of the CaseM/s SNC Lavalin International Inc., a non-resident
Canadian company, was engaged in providing consultancy services for
infrastructure projects. The company entered into an agreement with the
National ...
Director of Income Tax vs Various Assessees – No Interest Under Section 234B Where Income is Subject to TDS | Delhi High Court Following DIT v. Mitsubishi Corporation
Facts of the
Case
Multiple appeals were filed by the Income Tax Department against
different assessees.
The sole issue involved in these appeals was the charging of
interest under Section 234B of t...