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Commissioner of Income Tax (International Taxation)-3 vs Travelport Global Distribution System B.V. – No Substantial Question of Law on Attribution of Profits to Indian Operations (Delhi High Court)
Facts of the
CaseThe Revenue filed multiple appeals challenging a common
order of the Income Tax Appellate Tribunal dated 13.10.2021 concerning
various assessment years.The dispute centered around profit attribution
...
Indian Renewable Energy Development Agency Ltd. vs Pr. Commissioner of Income Tax (Delhi High Court, 2023) – Limitation under Section 153 IT Act on Set-Aside Assessments
Facts of the
CaseThe petitioner, Indian Renewable Energy
Development Agency Ltd., filed income tax returns for Assessment Years (AY)
1998–99 to 2009–10 under Section 139 of the Income Tax Act, 1961. These were
sc...
Commissioner of Income Tax (International Taxation)-3 vs Travelport Global Distribution System B.V. – No Substantial Question of Law on Profit Attribution (Delhi High Court)
Facts of the
CaseThe present matter pertains to multiple appeals
filed by the Revenue before the Delhi High Court challenging a common order
dated 13.10.2021 passed by the Income Tax Appellate Tribunal (ITAT) concerni...
Commissioner of Income Tax (International Taxation)-3 vs UT Starcom Inc. (Delhi High Court) – Deduction of Liquidated Damages under Income Tax Act (AY 2008–09)
Facts of the
CaseThe present appeal pertains to Assessment Year
2008–09, wherein the Revenue challenged the order of the Income Tax
Appellate Tribunal dated 28.07.2021.The respondent/assessee had initially created a...
PR. Commissioner of Income Tax-7 vs Trojan Developers Pvt. Ltd. (Delhi High Court) – Section 263 Revision Invalid Where AO Conducted Proper Inquiry on Share Premium u/s 56(2)(viib)
Facts of the
CaseThe present appeal pertains to Assessment Year
2014–15, wherein the assessee, Trojan Developers Pvt. Ltd., filed its return
declaring income of ₹11,43,240. The case was selected for limited scruti...
GoDaddy.com LLC vs Assistant Commissioner of Income Tax & Ors. (Delhi High Court) – Domain Registration Fees Not Royalty u/s 9(1)(vi) of Income Tax Act
Facts of the
Case
The assessee, GoDaddy.com LLC, is a US-based company engaged in:
Domain name registration
Web hosting
Web designing
It operates as an accredited registrar with ICANN.
The Asse...
Principal Commissioner of Income Tax vs B.L. Kashyap and Sons Ltd (Delhi High Court) – Section 142(2A), 142(2C) | Validity of Extension of Time for Special Audit
Facts of the CaseThe
present appeals were filed by the Revenue before the Delhi High Court challenging
a common order passed by the Income Tax Appellate Tribunal (ITAT) dated
30.09.2020 concerning Assessment Years 200...
PR. Commissioner of Income Tax (Central) vs Soul Space Projects Ltd. – Delhi High Court (Section 142(2A), 142(2C), 153A, 153B) – Validity of Extension of Special Audit Time & Limitation
Facts of the
CaseThe present matter arose from appeals filed by the
Revenue against a common order of the Income Tax Appellate Tribunal concerning
Assessment Years 2007–08 and 2008–09. The assessee, engaged in con...
Principal Commissioner of Income Tax (Central) vs B.L. Kashyap and Sons Ltd. – Delhi High Court on Validity of Extension of Time under Section 142(2C) of Income Tax Act
Facts of the Case
The Revenue filed multiple appeals challenging a common order of
the Income Tax Appellate Tribunal.
The dispute related to Assessment Years 2004–05 to 2008–09.
The core issue arose fro...
Akums Drugs and Pharmaceuticals Limited vs Deputy Commissioner of Income Tax, Delhi-1 – Reassessment u/s 147/148 Invalid due to Change of Opinion & Audit Objection (Delhi High Court)
Facts of the
CaseThe petitioner, Akums Drugs and Pharmaceuticals
Limited, filed its return of income for AY 2011-12, which was subjected to
scrutiny assessment under Section 143(3). During scrutiny, the Assessing
Off...