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Block Period under Section 153C to Be Reckoned from Date of Satisfaction Note; AY Falling Outside Ten-Year Block Cannot Be Reopened: PCIT-Central-1 vs. Amol Awasthi (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 13.09.2024 passed by the Income
Tax Appellate Tribunal in ITA No. 1343/Del/2024 for Assessment Year 201...
Penalty under Section 271(1)(c) Unsustainable Where Notice Does Not Specify Charge and Issue Is Debatable; No Substantial Question of Law: PCIT-7 vs. Quippo Telecom Infrastructure Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 06.03.2020 passed by the Income
Tax Appellate Tribunal in respect of Assessment Year 2010-11, whereby t...
Commission Income and Subscription Fees from Sale of Journals Not Taxable as Fees for Technical Services; Issue Covered by Binding Precedents: CIT (International Taxation-3) vs. Springer Nature Customer Service Centre GmbH (Delhi HC)
Facts of the
CaseThe Revenue filed appeals under Section 260A of the
Income-tax Act challenging a common order dated 05.07.2024 passed by the Income
Tax Appellate Tribunal for Assessment Years 2020-21 and 2021-22. The...
Centralised Marketing and Reservation Support Services Not Taxable as Royalty or Fees for Included Services; Issue Covered by Binding Precedents: CIT-IT-3 vs. Six Continents Hotels Inc. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 09.05.2024 passed by the Income
Tax Appellate Tribunal in favour of Six Continents Hotels Inc. for Asse...
Reassessment Proceedings Barred Post CIRP Approval; Clean Slate Doctrine Applies to Income Tax Dues Not Provided in Resolution Plan: Surya Manufacturing Pvt. Ltd. vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Surya Manufacturing Private
Limited, challenged an order dated 10.04.2024 passed under Section 148A(d) of
the Income-tax Act for Assessment Year 2017-18, holding it to be a fit case fo...
Writ Not Entertained Where Effective Appellate Remedy Exists; Jurisdiction under Section 127 Found Valid, Liberty Granted to Pursue Statutory Appeal: Supershine Laundry Systems Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the
CaseThe petitioner, Supershine Laundry Systems Private
Limited, filed writ petitions challenging reassessment orders dated 20.03.2025
passed under Section 147 of the Income-tax Act for the relevant assess...
Section 148 Notice Issued Beyond Permissible Period After Ashish Agarwal Regime Held Time-Barred; Reassessment Quashed: Saroj Mehndi vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, Saroj Mehndi, challenged a notice
dated 11.07.2022 issued under Section 148 of the Income-tax Act for Assessment
Year 2014-15 on the ground that it was barred by limitation. An earlier...
Section 153C Notices Quashed in Absence of Incriminating Material Belonging to Assessee and Having Bearing on Relevant Years: R.C. Jewellers Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the
CaseThe petitioner, R.C. Jewellers Pvt. Ltd.,
challenged separate notices dated 26.12.2019 issued under Section 153C of the
Income-tax Act for Assessment Years 2012-13 to 2017-18, along with an order
dat...
Depreciation on Bank Securities, Pension Fund Contribution and Section 14A Disallowance Covered by Earlier Decisions; No Substantial Question of Law: PCIT-7 vs. Punjab and Sind Bank (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 07.02.2024 passed by the Income
Tax Appellate Tribunal in ITA No. 8688/Del/2019 for Assessment Year 201...
Reassessment Beyond Three Years Invalid Where Alleged Escapement Below ₹50 Lakh and Not Linked to Single Asset or Event; Section 149(1A) Misapplied: Mohd Athar Anjum vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Mohd Athar Anjum, filed his return
of income for Assessment Year 2018-19 on 21.11.2018 declaring total income of
₹19,11,290. A survey under Section 133A was conducted on 01.09.2022 i...