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CIT (International Taxation) vs Saif Partner India IV Ltd – Delhi High Court | Section 263 Revision Invalid Without Twin Conditions (ITA 809/2023)
Facts of the
CaseThe case pertains to an appeal filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), which had
set aside the revisionary order passed under Section 263.The Assessing ...
Hyatt International Southwest Asia Ltd. vs. Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 | Permanent Establishment & Profit Attribution Despite Global Losses
Facts of the
CaseHyatt International Southwest Asia Ltd., a
UAE-based company, was engaged in providing hotel management and strategic
advisory services to hotels in India. The Indian tax authorities held that the
co...
PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 vs SANJAY SINGHAL (Delhi High Court) – Reopening Beyond Limitation u/s 149 Not Permissible u/s 150 | ITA 807/2023
Facts of the CaseThe case
pertains to addition made by the Assessing Officer (AO) amounting to ₹11.35
crores on account of alleged undisclosed income arising from trading activities
in commodities such as pulses and...
Commissioner of Income Tax (Central-1) vs RRPR Holding Pvt. Ltd. – Section 14A Disallowance Cannot Exceed Exempt Income | Delhi High Court
Facts of the
CaseThe appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT) for Assessment Year 2009–10.The Assessing Officer invoked Section 14A read with
Rule 8D and made...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of Permanent Establishment Profits Despite Global Losses under Article 7 DTAA & Income Tax Act
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, was engaged in providing hotel management and
oversight services in India. It entered into agreements with Indian hotel
own...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of Permanent Establishment Profits Despite Global Losses under Article 7 DTAA & Income Tax Act
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, was engaged in providing hotel management and
oversight services in India. It entered into agreements with Indian hotel
own...
Teekam Singh vs. Income Tax Officer: Appeal under Section 147 & 144 for AY 2011-12 - Non-cooperation due to Imprisonment and Restoration of Appeal for Re-adjudication
Facts of the
Case:The appeal concerns the assessment for the year
2011-12 of Sh. Teekam Singh against the Income Tax Officer (ITO), Ward-5(2)(4),
Noida, with respect to proceedings under section 147 r.w.s. 144 of the
...
Anil Kumar HUF vs ITO, Karnal – Delay in Filing Form 10-IE Due to Technical Glitch Cannot Deny Benefit u/s 115BAC (ITAT Delhi)
Facts of the
CaseThe assessee, Anil Kumar HUF, filed its
return of income for AY 2021–22 and intended to opt for the concessional tax
regime under Section 115BAC. However, the prescribed Form 10-IE was not filed wit...
Mechanical Approval under Section 153D Invalidates Search Assessment – ITAT Delhi in Kavita Jain & Others vs DCIT
Facts of the CaseA search under Section 132 was conducted in a group of connected
assessees, including the present assessees. Pursuant to the search, assessments
were framed under Section 143(3) read with Section 153A....
Mechanical Approval under Section 153D Invalidates Search Assessment – ITAT Delhi in Kavita Jain & Others vs DCIT
Facts of the CaseA search under Section 132 was conducted in a group of connected
assessees, including the present assessees. Pursuant to the search, assessments
were framed under Section 143(3) read with Section 153A....