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The Pr. Commissioner of Income Tax-4 vs Honeywell International (India) Pvt. Ltd. | Delhi High Court | ITA 878/2018 | Transfer Pricing – Functional Dissimilarity of Comparables
Facts of the CaseThe present appeal pertains to Assessment Year
2007–08, wherein the Revenue challenged the order dated 30.06.2017 passed
by the Income Tax Appellate Tribunal.The respondent/assessee, Honeywell Intern...
Valley Iron and Steel Co. Ltd. vs Principal Commissioner of Income Tax, Central-1 (Delhi High Court) – Section 68 Addition Upheld for Unexplained Loan Transaction (AY 2018–19)
Facts of the
CaseThe appellant, Valley Iron and Steel Co. Ltd.,
received ₹14,00,000 credited in its accounts during AY 2018–19, allegedly as a
loan from Gee Wire Pvt. Ltd. (GWPL).A loan agreement dated 01.07.2017 ...
Triveni Enterprises Limited vs Income Tax Officer-25(3) & Anr. (Delhi High Court, 2023) – Challenge to Section 148 Notice & Constitutional Validity of Section 115BBE Dismissed
Facts of the
CaseOrders passed under Section 148A(d) of the Income Tax Act dated 25
July 2022.
Notices issued under Section 148 for Assessment Years 2015–16,
2016–17, and 2017–18.
Constitutional ...
Bombardier Transportation India Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Transfer Pricing – Determination of Arm’s Length Price (ALP) under Income Tax Act
Facts of the
Case
The assessee, Bombardier Transportation India Pvt. Ltd., was
engaged in manufacturing and supplying bogies/wagons to its Associated
Enterprise (AE), Bombardier Transportation GmbH.
The...
Habitat Infracon Private Limited vs Income Tax Officer Ward 11(1), Delhi & Ors. – Reassessment Notice Quashed as Time-Barred under Sections 148 & 148A of Income Tax Act
Facts of the
CaseA notice under Section 148 of the Income Tax Act, 1961 dated 30.06.2021
was allegedly issued.
However, the notice was actually communicated via email only on
16.07.2021.
Subsequent not...
Pr. Commissioner of Income Tax (Central-1) vs Blue Coast Hotels Ltd. – No Disallowance under Section 14A in Absence of Exempt Income (Delhi High Court)
Facts of the
CaseThe appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal dated 17.03.2023 concerning
Assessment Year 2016–17. The Assessing Officer had made a disallowance
amo...
Commissioner of Income Tax (International Taxation)-1 vs A B Sciex Pte Ltd (Delhi High Court) – Permanent Establishment & Arm’s Length Principle Remand Case (AY 2017-18 to 2019-20)
Facts of the
Case
The Revenue filed appeals against orders of the Income Tax
Appellate Tribunal (ITAT) for AY 2017-18, 2018-19, and 2019-20.
The Tribunal had primarily examined whether the assessee had a Perm...
PR. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. & Connected Matters (ITA 329/2022 & Ors.) – Delhi High Court | Appeals Closed Due to CIRP Proceedings
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging various orders passed by the Income Tax Appellate Tribunal
(ITAT) concerning multiple assessment years ranging from AY 2010–11 to AY...
Commissioner of Income Tax (International Taxation)-3 vs Zaheer Mauritius | Delhi High Court | Section 2(28A), India-Mauritius DTAA (Articles 11 & 13) | Capital Gains vs Interest on CCDs
Facts of the
Case
The respondent/assessee, Zaheer Mauritius, along with Vatika Pvt.
Ltd., invested in Compulsorily Convertible Debentures (CCDs) issued
by SH Tech Park Developers Pvt. Ltd.
CCDs were iss...
M/s Sahu Exports vs Assistant Commissioner of Income Tax & Anr. (Delhi High Court, 2023) – Reassessment u/s 148 Quashed Due to Lack of Independent Application of Mind
M/s Sahu Exports vs Assistant Commissioner of Income Tax & Anr.
(Delhi High Court, 2023) – Reassessment u/s 148 Quashed Due to Lack of
Independent Application of Mind Facts of the
CaseThe petitioner, M/s Sa...