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Commissioner of Income Tax vs. Ankitech Pvt. Ltd. | Delhi High Court on Taxability of Deemed Dividend under Section 2(22)(e) in the Hands of Non-Shareholder Concern
Facts of the Case
The assessee company received advances/loans from another closely
held company.
Certain individuals held substantial shareholding in both the
lending company and the recipient concern.
...
Commissioner of Income Tax vs Ankitech Pvt. Ltd. | Landmark Delhi High Court Ruling on Deemed Dividend Under Section 2(22)(e) of the Income Tax Act
Facts of the
CaseThe present batch of appeals involved a common
question regarding the interpretation of Section 2(22)(e) of the Income Tax
Act, 1961 dealing with deemed dividend. The lead matter concerned Ankitech Pv...
Commissioner of Income Tax XVI vs Sh. Fumio Goto & Connected Matters – Applicability of Section 10(10CC), Section 17(2), and Section 40 of the Income Tax Act, 1961
Facts
of the Case:The
batch of appeals involved multiple foreign nationals deputed to work in India
for Indian subsidiaries of their foreign employers. The core issues concerned
the tax treatment of:
Employer-paid ...
Commissioner of Income Tax v. Ankitech Pvt. Ltd. & Connected Matters | Delhi High Court on Taxability of Deemed Dividend under Section 2(22)(e) of the Income Tax Act
Facts of the Case
The assessees in the batch of appeals were companies or concerns
which had received loans, advances, or financial accommodations from
closely-held companies.
The lending companies po...
Commissioner of Income Tax v. Ankitech Pvt. Ltd. & Connected Matters | Delhi High Court on Taxability of Deemed Dividend under Section 2(22)(e) of the Income Tax Act
Facts of the Case
The assessees in the batch of appeals were companies or concerns
which had received loans, advances, or financial accommodations from
closely-held companies.
The lending companies posses...
AREVA T&D SA vs The Asst. Director of Income Tax & Ors. | Delhi HC Case on Income Escaping Assessment & Certificate Under Section 197
Facts of the Case
The
petitioner, AREVA T&D SA, was awarded multiple contracts by Power Grid
Corporation of India Ltd. (PGCIL) for onshore and offshore supply and
services (Page 3–5).
PGCIL
...
Commissioner of Income Tax v. Nestle India Ltd. | Allowability of Royalty Payment to Associated Enterprises under Section 40A(2), Section 92 and Article 9 of India-Switzerland DTAA | Delhi High Court
Facts of the Case
Nestle India Ltd. was engaged in the manufacture and marketing of
food products and beverages in India.
The company paid substantial royalty and technical know-how fees to
its foreign gr...
Commissioner of Income Tax v. Nestle India Ltd. | Allowability of Royalty Payment to Associated Enterprises under Section 40A(2), Section 92 and Article 9 of India-Switzerland DTAA | Delhi High Court
Facts of the Case
Nestle India Ltd. was engaged in the manufacture and marketing of
food products and beverages in India.
The company paid substantial royalty and technical know-how fees to
its foreign gr...
Commissioner of Income Tax vs. Goyal M.G. Gases Pvt. Ltd. (2011) – Interest on Sticky Loans Not Taxable Under Real Income Theory Despite Mercantile Accounting | Delhi High Court
Facts of the CaseThe assessee company was engaged in financing
activities through loans, Inter-Corporate Deposits (ICDs), bill discounting,
and similar transactions.For accounting purposes under the Companies Act,
the...
Fab India Overseas Pvt. Ltd. vs Commissioner of Income Tax (Delhi High Court) – Scope of Revision under Section 263, Transfer Pricing Reference to TPO, and Distinction Between Lack of Inquiry and Inadequate Inquiry
Facts of the Case
The assessee, Fab India Overseas Pvt. Ltd., was engaged in export
and local trading of handloom products and readymade garments.
For Assessment Year 2004-05, it filed its return declaring inco...