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PR. Commissioner of Income Tax–1, Delhi vs M/s Dart Infrabuild (P) Ltd. (Delhi High Court) – Invalid Reassessment Due to Improper Service of Notice u/s 148 & Non-Issuance of Mandatory Notice u/s 143(2) | Sections 147, 148, 143(2), 144, 292BB, 68, 14A of Income-tax Act
Facts of the
CaseThe present appeal arose from Assessment Year
2010–11 wherein the Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT).The assessee, M/s Dart Infrabuild Pvt. Ltd., had
changed i...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP (Delhi High Court, AY 2013–14) – Appeal Dismissed Following Sheraton International Precedent
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the order dated 07.01.2020 passed by the Income
Tax Appellate Tribunal (ITAT) concerning Assessment Year 2013–14.The a...
Commissioner of Income Tax (International Taxation)-3 vs Westin Hotel Management LP (Delhi High Court) – ITA 633/2023 | AY 2014–15 | No Substantial Question of Law
Facts of the Case
The
Revenue preferred an appeal before the Delhi High Court against the ITAT
order.
The
dispute pertains to Assessment Year 2014–15.
During
the hearing, it was acknowle...
PR. Commissioner of Income Tax–3 vs Devata Tradelink Ltd. (Delhi High Court) – Section 14A Disallowance Cannot Exceed Exempt Income | AY 2008-09
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), which
deleted disallowance made under Section 14A.
The assessee earned exempt income of...
Commissioner of Income Tax (International Taxation)-3 vs Ricardo U.K. Limited – No Further Profit Attribution to PE When Arm’s Length Remuneration Paid [Section 9, India-UK DTAA]
Facts of the
CaseThe case pertains to Assessment Year 2016–17. The
respondent, Ricardo U.K. Limited, is a company incorporated in the United
Kingdom and is a tax resident of the UK under Article 4 of the India-UK Do...
Deepak Modi vs Assistant Commissioner of Income Tax Circle 46(1) & Anr. | Delhi High Court | Reassessment u/s 148A(d) Set Aside for Violation of Natural Justice (No Personal Hearing)
Facts of the
CaseThe present writ petition pertains to Assessment
Year 2019–2020, wherein the petitioner, Deepak Modi, was subjected to
reassessment proceedings on allegations of availing accommodation entries
thro...
Shourya Estates Pvt. Ltd. vs Income Tax Officer, Ward 23(2), New Delhi & Anr. (Delhi High Court) – Reopening of Assessment under Section 148 Quashed
Facts of the
CaseThe present writ petition pertains to Assessment
Year (AY) 2011–12. The petitioner, Shourya Estates Pvt. Ltd. (SEPL), challenged
the legality of a notice dated 31.03.2018 issued under Section 148 of...
Intertek India Private Limited vs Income Tax Officer, Ward International Taxation (Delhi High Court, 2023) – Section 201 & 195 Income Tax Act | TDS on Management Fees
Facts of the
CaseThe petitioner, Intertek India Private Limited,
challenged:
Notice dated 10.10.2017 issued under Section 201 of the Income-tax
Act, 1961, and
Order dated 25.03.2021 rejecting objections agai...
M/s FIS Payment Solutions & Services India Pvt. Ltd. vs Deputy Commissioner of Income Tax-9(1) & Anr. (Delhi High Court, 2023)
Facts of the
CaseThe petitioner, M/s FIS Payment Solutions &
Services India Pvt. Ltd., filed a writ petition seeking release of a refund
amounting to ₹62.14 crores under Section 143(1) of the Income-tax Act, 196...
PR. Commissioner of Income Tax-04, Delhi vs M/s Inductis India Pvt. Ltd. – No Disallowance u/s 14A & No TP Adjustment on Receivables for Debt-Free Company | Delhi High Court
Facts of the
CaseThe assessee, a wholly owned subsidiary engaged in
IT-enabled back-office and analytics services, filed its return declaring
income of ₹16.42 crores. The case was selected for scrutiny and proceedin...