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PR Commissioner of Income Tax, Central-3 vs Shyam Sunder Jindal (Delhi High Court) – Section 254(2) | Notional Interest on Foreign Bank Account | No Addition Without Incriminating Material
Facts of the
CaseThe Revenue filed appeals challenging the order of
the Income Tax Appellate Tribunal (ITAT) dated 20.12.2019 passed under Section
254(2) of the Income-tax Act.The case involved assessment years 2008â€...
Principal Commissioner of Income Tax–1 vs Anand Divine Developers Pvt. Ltd. (Delhi High Court) – Disallowance of Management Fees Deleted | Sections 143(2), 142(1), 37, Limitation Act Section 5
Facts of the
Case
The assessee filed its Return of Income declaring losses for AY
2013–14 and AY 2014–15.
During scrutiny assessment, the Assessing Officer (AO) observed
that the assessee paid subst...
D Commissioner of Income Tax vs MS Jite Shipyard Ltd – Section 14A Disallowance Cannot Exceed Exempt Income (Delhi High Court ITA 757/2023)
Facts of the CaseThe
appeal was filed by the Revenue challenging the order of the Income Tax
Appellate Tribunal dated 27.03.2023. The dispute arose in relation to
Assessment Year 2015–16 concerning disallowance unde...
D Commissioner of Income Tax vs MS Jite Shipyard Ltd – Section 14A Disallowance Cannot Exceed Exempt Income (Delhi High Court ITA 757/2023)
Facts of the CaseThe
appeal was filed by the Revenue challenging the order of the Income Tax
Appellate Tribunal dated 27.03.2023. The dispute arose in relation to
Assessment Year 2015–16 concerning disallowance unde...
PR. Commissioner of Income Tax, Delhi–8 vs M/s Sony India Pvt. Ltd. – AMP Expenses, Arm’s Length Price & Bright Line Test | Delhi High Court (ITA 10/2023, AY 2008–09)
Facts of the
Case
The appeal relates to Assessment Year 2008–09.
The Revenue challenged the order of the Income Tax Appellate
Tribunal (ITAT) dated 16.01.2019.
The dispute revolved around whether:
...
Principal Commissioner of Income Tax-1 vs Anand Divine Developers Pvt. Ltd. (Delhi High Court) – Disallowance of Management Fees & Onus of Proof under Income Tax Act
Facts of the
CaseThe respondent/assessee, Anand Divine Developers
Pvt. Ltd., filed its return of income declaring losses for AY 2013–14 and
AY 2014–15. During scrutiny proceedings initiated under Sections 143(2) a...
Principal Commissioner of Income Tax-1 vs Anand Divine Developers Pvt. Ltd. (Delhi High Court) – Disallowance of Management Fees & Onus of Proof under Income Tax Act
Facts of the
CaseThe respondent/assessee, Anand Divine Developers
Pvt. Ltd., filed its return of income declaring losses for AY 2013–14 and
AY 2014–15. During scrutiny proceedings initiated under Sections 143(2) a...
Principal Commissioner of Income Tax (International Tax)-1 vs GoDaddy.com LLC | Delhi High Court | Section 271(1)(c) Penalty on Alleged Royalty Income | AY 2013-14 & 2014-15
Facts of the
CaseThe dispute arose for Assessment Year 2014–15,
where the Revenue challenged the order of the Income Tax Appellate Tribunal
(ITAT), which upheld the deletion of penalty imposed under Section 271(1)(c...
PR. Commissioner of Income Tax–7 vs. Thapar Homes Ltd. (Delhi High Court) – Penalty Proceedings Time Limitation under Sections 271D, 269SS & 275(1)(c) of Income Tax Act
Facts of the
CaseThe Revenue filed an appeal challenging the order
of the Income Tax Appellate Tribunal (ITAT), which upheld the decision of the
Commissioner of Income Tax (Appeals) [CIT(A)].The case arose from allege...
Principal Commissioner of Income Tax (Central-1) vs Ashok Kumar Singh (Delhi High Court) – Protective Addition & Black Money Act Proceedings (AY 2014–15)
Facts of the
CaseThe present appeal pertains to Assessment Year
2014–15. The Revenue challenged the order of the Income Tax Appellate Tribunal
dated 19.04.2023.The Assessing Officer had made a protective
addition o...