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Samsung Electronics Co. Ltd. vs Deputy Commissioner of Income Tax (International Taxation) – Reopening of Assessment u/s 147/148 upheld due to Non-Disclosure of Royalty & FTS Income [Delhi High Court | ITA 916–920/2018]
Facts of the
CaseThe appellant, Samsung Electronics Co. Ltd., a
non-resident company incorporated in South Korea, filed appeals under Section
260A of the Income Tax Act, 1961 challenging a common order of the Income T...
Samsung Electronics Co. Ltd. vs Deputy Commissioner of Income Tax (International Tax) – Reopening of Assessment Valid for Non-Disclosure of Royalty & FTS Income under Sections 147/148 of Income Tax Act
Facts of the
Case
The assessee, a non-resident company incorporated in South Korea,
filed appeals against a common order of the Income Tax Appellate Tribunal.
A survey conducted at the premises of its I...
PR. Commissioner of Income Tax vs American Express India Pvt. Ltd. (2018) – Penalty u/s 271(1)(c) on Netting of Interest under Section 10B – Delhi High Court
Facts of the
CaseThe present case arises from an appeal filed by the
Revenue against the order of the Income Tax Appellate Tribunal, which upheld
the decision of the Commissioner of Income Tax (Appeals) deleting penal...
PR. Commissioner of Income Tax–18 vs Maharani of India (ITA 872–878/2017) | Delhi High Court | Low Tax Effect Appeals Dismissed under CBDT Circular No. 3/2018
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court for Assessment Years 2003–2004 to 2007–2008 against the respondent,
Maharani of India. These appeals were filed under Section 260A of...
PR. Commissioner of Income Tax-18 vs Maharani of India (Delhi High Court) – ITA 872–878/2017 | Low Tax Effect Appeals Dismissed under CBDT Circular No. 3/2018
Facts of the
CaseThe Revenue (Principal Commissioner of Income
Tax-18) filed multiple appeals before the Delhi High Court against the
respondent (Maharani of India) for Assessment Years 2003–2004 to 2007–2008.Duri...
PR. Commissioner of Income Tax-18 vs Maharani of India | Delhi High Court | Low Tax Effect Appeals Dismissed under CBDT Circular No. 3/2018 (Sections 260A, Income Tax Act)
Facts of the CaseThe present matter pertains to a batch of income tax appeals filed by the Revenue (PR. Commissioner of Income Tax-18) before the Delhi High Court concerning Assessment Years 2003–2004 to 2007–2008. T...
Samsung Electronics Co. Ltd. vs Deputy Commissioner of Income Tax (International Taxation) – Reassessment Valid for Non-Disclosure of Royalty & FTS Income under Sections 147/148 of Income Tax Act
Facts of the
CaseThe assessee, Samsung Electronics Co. Ltd., a
non-resident company incorporated in South Korea, filed appeals under Section
260A challenging the Income Tax Appellate Tribunal’s order which upheld th...
Samsung Electronics Co. Ltd. vs Deputy Commissioner of Income Tax (International Taxation) – Reassessment Valid on Non-Disclosure of Royalty & FTS Income under Sections 147/148 of Income Tax Act
Facts of the
Case
The assessee, a South Korea-based company, operated in India
through:
An Indian subsidiary engaged in manufacturing and trading consumer
electronics.
A branch office engaged i...
PR. Commissioner of Income Tax-18 vs Maharani of India | Delhi High Court | Low Tax Effect Appeals Dismissed under CBDT Circular No. 3/2018 Section 260A, Income Tax Act, 1961
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court concerning assessment years 2003–2004 to 2007–2008. During the
hearing, counsel for the Revenue submitted that the tax effect involve...
PR. Commissioner of Income Tax–6 vs National Housing Bank (Delhi High Court) – Section 36(1)(viii) & 271(1)(c) | Bona Fide Claim & Penalty for Concealment
Facts of the
Case
The respondent-assessee, National Housing Bank (NHB), is wholly
owned by RBI and engaged in promoting housing finance.
NHB claimed deduction under Section 36(1)(viii) for creating a
...