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PR. Commissioner of Income Tax–8 vs M/s Sony India Pvt. Ltd. (Delhi High Court) – AMP Expenses, Transfer Pricing Adjustment & Bright Line Test under Sections 92C & 92CA of the Income-tax Act, 1961
Facts of the CaseThe present case pertains to Assessment Year 2007–08, where
the Revenue challenged the order of the Income Tax Appellate Tribunal.The respondent/assessee, M/s Sony India Pvt. Ltd., a wholly
owned sub...
Shyam Sunder Jindal vs Assistant Commissioner of Income Tax – Delhi High Court (Section 153A) | Addition Without Incriminating Material Held Invalid
Facts of the CaseThe appellant/assessee was subjected to a search operation
conducted on 14.11.2011 under Section 132 of the Income-tax Act. Subsequently,
assessment proceedings were initiated under Section 153A for As...
AKUM DRUGS AND PHARMACEUTICALS LIMITED vs DEPUTY COMMISSIONER OF INCOME TAX, DELHI-1 – Reassessment under Section 148 quashed due to Change of Opinion and Lack of Independent Application of Mind
Facts of the
CaseThe petitioner filed its Return of Income for AY
2011–12, which was selected for scrutiny. During assessment proceedings,
detailed queries were raised, including those related to deduction claimed
...
PR. Commissioner of Income Tax (Central)-2 vs Versatile Polytech Pvt. Ltd. – Delay of 3 Years Not Condoned under Section 260A of Income Tax Act | Delhi High Court
Facts of the
CaseThe Revenue filed appeals against a common order
dated 15.03.2019 passed by the Income Tax Appellate Tribunal relating to
Assessment Years 2009–10 and 2014–15.The certified copy of the ITAT order ...
PR Commissioner of Income Tax, Central-3 vs Shyam Sunder Jindal (Delhi High Court) – Section 254(2) | Notional Interest on Foreign Bank Account | No Addition Without Incriminating Material
Facts of the
CaseThe Revenue filed appeals challenging the order of
the Income Tax Appellate Tribunal (ITAT) dated 20.12.2019 passed under Section
254(2) of the Income-tax Act.The case involved assessment years 2008â€...
PR Commissioner of Income Tax, Central-3 vs Shyam Sunder Jindal (Delhi High Court) – Section 254(2) | Notional Interest on Foreign Bank Account | No Addition Without Incriminating Material
Facts of the
CaseThe Revenue filed appeals challenging the order of
the Income Tax Appellate Tribunal (ITAT) dated 20.12.2019 passed under Section
254(2) of the Income-tax Act.The case involved assessment years 2008â€...
Principal Commissioner of Income Tax–1 vs Anand Divine Developers Pvt. Ltd. (Delhi High Court) – Disallowance of Management Fees Deleted | Sections 143(2), 142(1), 37, Limitation Act Section 5
Facts of the
Case
The assessee filed its Return of Income declaring losses for AY
2013–14 and AY 2014–15.
During scrutiny assessment, the Assessing Officer (AO) observed
that the assessee paid subst...
D Commissioner of Income Tax vs MS Jite Shipyard Ltd – Section 14A Disallowance Cannot Exceed Exempt Income (Delhi High Court ITA 757/2023)
Facts of the CaseThe
appeal was filed by the Revenue challenging the order of the Income Tax
Appellate Tribunal dated 27.03.2023. The dispute arose in relation to
Assessment Year 2015–16 concerning disallowance unde...
D Commissioner of Income Tax vs MS Jite Shipyard Ltd – Section 14A Disallowance Cannot Exceed Exempt Income (Delhi High Court ITA 757/2023)
Facts of the CaseThe
appeal was filed by the Revenue challenging the order of the Income Tax
Appellate Tribunal dated 27.03.2023. The dispute arose in relation to
Assessment Year 2015–16 concerning disallowance unde...
PR. Commissioner of Income Tax, Delhi–8 vs M/s Sony India Pvt. Ltd. – AMP Expenses, Arm’s Length Price & Bright Line Test | Delhi High Court (ITA 10/2023, AY 2008–09)
Facts of the
Case
The appeal relates to Assessment Year 2008–09.
The Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT) dated 16.01.2019.
The dispute revolved around whether:
...