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Commissioner of Income Tax Delhi vs M/s Maruti Udyog Ltd – Assessment of Interest Income under Section 80HHC(4A), Income Tax Act, 1961
Facts of the
Case
The Income Tax Appellate Tribunal had remitted the computation of
interest on inter-corporate deposits, securities, and bank deposits to the
Assessing Officer for fresh adjudication.
Th...
Comprehensive Judicial Analysis: Pitney Bowes India Pvt. Ltd. vs. Commissioner of Income Tax – Determining the Taxability and Classification of Non-Compete Fees under the Income Tax Act
Facts of the CaseThe appellant, Pitney Bowes India Pvt. Ltd., was incorporated
on April 23, 2004, as a wholly-owned subsidiary of Pitney Bowes Inc., USA, to
establish a direct presence in the Indian market. As part of ...
Comprehensive Analysis of Legal Precedents Regarding Mandatory Interest Under Section 234C: A Case Study of Bill & Peggy Marketing India Pvt Ltd vs. Assistant Commissioner of Income Tax
Facts of the CaseThe appellant, a company involved in marketing, was subject to
assessment for the financial year 2004-05. During this period, the company made
several payments toward advance tax to fulfill its obligat...
Commissioner of Income Tax vs. East India Syntex Limited: A Comprehensive Judicial Analysis on the Scope of Block Assessment Proceedings and the Classification of Capital vs. Revenue Expenditure
Facts of the CaseThe assessee, East India Syntex Limited, is engaged in the
manufacturing and production of polyester viscose blended yarn and 100%
polyester yarn. For the block assessment period of 1.4.1988 to 14.10.1...
BLB Limited vs. Assistant Commissioner of Income Tax: Analysis of Reassessment Proceedings and the "Change of Opinion" Doctrine
Facts of the Case
The petitioner, BLB Limited, filed its income tax return for
the Assessment Year (AY) 2003-04, declaring an income under Section 115JB of
the Income Tax Act, 1961. During the original scrutiny asse...
Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of Rule 8D and Section 14A
Facts of the CaseThe case consolidated three separate income tax appeals (ITA
277/2009, 460/2009, and 949/2009) concerning the assessment years 2004-05,
2000-01, and 2002-03. The dispute involved the Oriental Bank of C...
Commissioner of Income Tax vs. Oriental Bank of Commerce: Detailed Analysis of the Non-Retrospective Nature of Rule 8D and the Application of Section 14A of the Income Tax Act
Facts of the CaseThe appeals pertained to the assessment years 2000-01,
2002-03, and 2004-05 concerning the respondent, Oriental Bank of Commerce. The
dispute arose regarding the application of Rule 8D of the Income Ta...
Commissioner of Income Tax vs. M/S DCM Shriram Consolidated Ltd: Applicability of Rule 8D and Mechanism of Disallowance Under Section 14A of the Income Tax Act, 1961
Facts of the Case
Nature
of Appeal: The Appellant (Revenue) filed an appeal
under Section 260A of the Income Tax Act, 1961, directed against the order
of the Income Tax Appellate Tribunal (Tribunal) d...
M/s Genpact India vs. Assistant Commissioner of Income Tax: Legality of Unilateral Tax Refund Adjustments Under Section 245 and the Computational Treatment of Telecommunication Expenses for Deductions Under Section 10A of the Income Tax Act, 1961
Facts of the Case
The
petitioner, M/s Genpact India, is engaged in rendering IT-enabled services
and had established undertakings under the Software Technology Park Scheme
(STPS).
For
the Ass...
Atsushi Yoshida vs. Assistant Commissioner of Income Tax: Validity of Reopening Assessment Under Section 147 Post Revised Return and Form 16 Alterations
Facts of the Case
Employment
& Compensation: The petitioners were employees of M/s
Tokio Marine and Nichido Fire Inc. Limited and were paid a tax-free salary
in India, meaning the income tax compo...