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Prosecution under Section 276C(1) Cannot Continue After Settlement Commission Order Granting Penalty Immunity: Supreme Court, (VIJAY KRISHNASWAMI @ KRISHNASWAMI VIJAYAKUMAR VS THE DEPUTY DIRECTOR OF INCOME TAX )
The Supreme Court examined the legality of continuation of
prosecution under Section 276C(1) of the Income Tax Act, 1961, after the Income
Tax Settlement Commission had passed an order granting immunity from penalty
u...
Limitation Period under Section 144C vis-à-vis Section 153 of the Income-tax Act: Supreme Court Clarifies DRP Timelines, (ASSISTANT COMMISSIONER OF INCOME TAX VS SHELF DRILLING RON TAPPMEYER LIMITED)
The issue before the Supreme Court concerned the correct
interpretation of the limitation provisions under Section 153 of the Income-tax
Act, 1961, in cases where the special assessment procedure under Section 144C,
i...
Hotel Premises Constitute Fixed Place PE: Supreme Court in Hyatt International Southwest Asia Ltd. Case, (Hyatt International Southwest Asia Ltd. v. Additional Director of Income Tax)
The Supreme Court, in Hyatt
International Southwest Asia Ltd. v. Additional Director of Income Tax,
examined whether the appellant, a company incorporated in Dubai and a tax
resident of the United Arab Emirates, had a...
Reduction of Share Capital Constitutes ‘Transfer’ Under Section 2(47): Supreme Court Reaffirms Capital Loss Allowability in PCIT v. Jupiter Capital Pvt. Ltd. (2025)
The
Supreme Court has reiterated the settled legal position that reduction of share
capital leading to extinguishment of shareholder rights amounts to a “transfer”
within the meaning of Section 2(47) of the Income...
Offence under Section 276CC of Income Tax Act: Supreme Court Clarifies “First Offence” and Compounding Guidelines VINUBHAI MOHANLAL DOBARIA Vs CHIEF COMMISSIONER OF INCOME TAX & ANR
The Supreme Court examined the scope and
interpretation of Section 276CC of the Income Tax Act, 1961, and the
applicability of the Guidelines for Compounding of Offences under Direct Tax
Laws, 2014, in the context of ...
Prosecution under Section 276C(1) Cannot Continue After Settlement Commission Order Granting Penalty Immunity: Supreme Court, VIJAY KRISHNASWAMI VERSUS THE DEPUTY DIRECTOR OF INCOME TAX (INVESTIGATION)
The Supreme Court examined the legality of
continuation of prosecution under Section 276C(1) of the Income Tax Act, 1961,
after the Income Tax Settlement Commission had passed an order granting
immunity from penalty u...
Limitation Period under Section 144C vis-à-vis Section 153 of the Income-tax Act: Supreme Court Clarifies DRP Timelines, Assistant Commissioner of Income Tax (International Taxation) & Others Versus Shelf Drilling Ron Tappmeyer Ltd. Etc.
The issue before the Supreme Court
concerned the correct interpretation of the limitation provisions under Section
153 of the Income-tax Act, 1961, in cases where the special assessment
procedure under Section 144C, i...
TDS Credit Cannot Be Denied Due to System Mismatch in Form 26AS – Relief to Deductee | Sumit Devendra Rajani v. ACIT (Gujarat HC)
In many cases, assessees are confronted with tax demands solely on the ground that the credit of Tax Deducted at Source (TDS) claimed by them is not fully or correctly reflected in Form 26AS, despite the fact that tax ha...
No Transfer Pricing Adjustment on Interest for Delayed AE Receivables Where Working Capital Adjustment Granted: ITAT Delhi in ERM India Pvt. Ltd. v. DCIT
In
ERM India Private Limited, Gurugram v. Assessment Unit (DCIT, Circle 7(1),
Delhi), the Delhi Bench of the Income Tax Appellate Tribunal examined the
validity of a transfer pricing adjustment made on account of alle...
Offshore Supply Not Taxable in India and No Supervisory or Fixed Place PE Established: ITAT Delhi in SAIC Motor Corporation Ltd. v. ACIT
In
SAIC Motor Corporation Ltd., China v. Assistant Commissioner of Income Tax
(International Taxation), Gurgaon, the Delhi Bench of the Income Tax
Appellate Tribunal examined whether profits from offshore supply of KD...