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Shourya Infrastructure Pvt. Ltd. vs Income Tax Officer, Ward 23(2) & Anr. | Reassessment u/s 147 Quashed on Grounds of Change of Opinion & Invalid Approval u/s 151 (Delhi High Court)
Facts of the
CaseThe petitioner, Shourya Infrastructure Pvt. Ltd.,
engaged in real estate business, filed its return for AY 2011–12 which was
scrutinized under Section 143(3) of the Income Tax Act, 1961. During scru...
Triveni Enterprises Limited vs Income Tax Officer-25(3) & Anr. | Delhi High Court on Validity of Section 115BBE & Reassessment under Sections 148 & 148A(d) of Income Tax Act
Facts of the
CaseThe petitioner, Triveni Enterprises Limited,
filed writ petitions challenging:
Orders dated 25 July 2022 passed under Section 148A(d) of
the Income Tax Act.
Notices issued under Section 148 ...
R. Commissioner of Income Tax-1 vs Amrapali Silicon City Pvt. Ltd. & Connected Matters (Delhi High Court, 2023)
Facts of the
CaseThe present batch of appeals was filed by the
Revenue (Principal Commissioner of Income Tax-1) against various entities of
the Amrapali Group, including Amrapali Silicon City Pvt. Ltd., Amrapali
Sapp...
Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. (Delhi High Court) – Section 260A Income Tax Appeal on Tribunal Order & Corporate Insolvency Impact
Facts of the Case
The Revenue preferred an appeal before the Delhi High Court against
the order passed by the ITAT.
The respondent/assessee, part of the Amrapali Group, was undergoing
Corporate Ins...
Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. | Delhi High Court | ITA 329/2022 | Income Tax Appeal on CIRP & Maintainability of Proceedings
Facts of the
Case
The Revenue filed an appeal under Section 260A of the Income Tax
Act before the Delhi High Court against the order of the Income Tax
Appellate Tribunal.
The respondent company belonged...
Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. | Delhi High Court | Section 260A read with Sections 40(a)(i) & 195 of Income Tax Act – Disallowance on Payments to Non-Residents & DTAA Override
Facts of the
CaseThe Revenue filed an appeal before the Delhi High
Court challenging the order of the Income Tax Appellate Tribunal (ITAT), which
had deleted disallowances made under Section 40(a)(i) of the Income Tax...
PR. COMMISSIONER OF INCOME TAX–1 vs AMRAPALI SILICON CITY PVT. LTD. (Delhi High Court) – Section 260A Appeal | Liberty to Revive Appeal in Insolvency Context
Facts of the
CaseThe appeal was filed by the Revenue under Section
260A of the Income-tax Act challenging the order passed by the Income Tax
Appellate Tribunal (ITAT) in favour of the assessee, Amrapali Silicon ...
PR. COMMISSIONER OF INCOME TAX-1 vs AMRAPALI SILICON CITY PVT. LTD. (Delhi High Court) – Section 260A | Income Tax Appeal on Tribunal Order & Insolvency Proceedings
Facts of the
Case
The Revenue filed multiple appeals (including ITA 329/2022) against
orders passed by the ITAT concerning different assessment years.
The respondent company, part of the Amrapali Group, was
...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 [Section 260A | DTAA | Permanent Establishment | Royalty vs Business Income]
Facts of the
CaseThe assessee, a UAE-based company, provided
strategic and advisory services to hotels in India under Strategic Oversight
Services Agreements (SOSA). It claimed that such services were rendered from
o...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 (Section 260A | Permanent Establishment | DTAA India-UAE | Royalty vs Business Income)
Facts of the
CaseThe appellant, Hyatt International Southwest Asia
Ltd., is a company incorporated in the UAE and a tax resident under the
India-UAE Double Taxation Avoidance Agreement (DTAA). The appellant entered in...