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Commissioner of Income Tax vs. Keihin Panalfa Ltd. – Pro-Rata Apportionment of Transfer Pricing Adjustments under Section 92CA
Facts of the Case
The
Assessee's Business: Keihin Panalfa Ltd. (the Assessee/Respondent)
manufactures and sells air-conditioners for cars manufactured by Honda
Siel Cars India Ltd.
International
...
Commissioner of Income Tax-V vs. Kapil: Capital Gains Exemption Under Section 54F and the Impact of Fractional Property Co-Ownership
Facts of the Case
Deduction
Claims: The Respondent-Assessee filed his return of
income for the Assessment Year (AY) 2007-08 declaring an income of
₹2,78,53,090. In the return, the Assessee claimed a...
Commissioner of Income Tax (Central II) vs. P.D. Associates (P) Ltd. — Scope of Substantial Question of Law under Section 260A of the Income Tax Act
1. Facts of the CaseThe Revenue (Commissioner of Income Tax, Central II) filed a
series of Income Tax Appeals (ITA No. 461/2015, 463/2015, 464/2015, 465/2015,
468/2015, 469/2015, and the lead appeal ITA No. 444/2015) b...
COMMISSIONER OF INCOME TAX vs. SRI VIJAY SINGH KADAN: Determination of Agricultural Land Status under Section 2(14)(iii)(b) of the Income Tax Act – Distance Measurement Method
Facts of the Case
Assessee
Property Sale: During the assessment proceedings for
Assessment Year (AY) 2006-07, the Assessing Officer (AO) noted that the
Assessee (Respondent) sold $5.9625$ acres of lan...
Commissioner of Income Tax vs. Vodafone Essar Mobile Service Ltd. & Ors. (Under Sections 391 to 394 of the Companies Act)
Facts of the Case
Scheme
Approval: Two separate sets of corporate entities,
Vodafone and Bharti, filed claims for corporate mergers and demergers
before the learned Company Judge.
Statutory
F...
Commissioner of Income Tax (Central)-I vs. Chetan Gupta: Mandatory Service of Jurisdictional Notice Under Section 148 of the Income Tax Act, 1961
Facts of
the Case
Assessee
Profile & Filings: The Assessee, Mr. Chetan Gupta, filed
his original return of income for Assessment Year (AY) 2001–2002 on
October 11, 2001, declaring an inco...
Commissioner of Income Tax vs. Morgan Securities & Credits Pvt. Ltd. | Prospectivity of Rule 8D Under Section 14A of the Income Tax Act
Facts of the CaseThe Revenue (Income Tax Department) filed two appeals (ITA
589/2014 and ITA 590/2014) challenging the orders passed by the Income Tax
Appellate Tribunal (ITAT). The challenged ITAT orders were dated Ja...
Pr. Commissioner of Income Tax -5 vs. Kay Kay Royal Apartments Pvt. Ltd. (With Connected Appeals) – High Court of Delhi Rules No Deemed Dividend Addition Under Section 2(22)(e) of Income Tax Act, 1961 If Assessee Is Not A Shareholder In Lending Company
Facts of the Case
Filing
of Return: The Respondent-Assessee filed its return of
income for the Assessment Year (AY) 2006-07, declaring a financial loss of
Rs. 59,213.
Scrutiny
Assessment: The...
Oriental Insurance Company vs. Commissioner of Income Tax: Validity of Reassessment Under Section 147 and Taxability of Insurance Company's Investment Profits
Facts of the Case
Assessee
Profile: The Appellant, Oriental Insurance Company,
is a subsidiary of the General Insurance Corporation of India, principally
engaged in the non-life (general) insurance bu...
Commissioner of Income Tax-IV vs. Pritam | Taxability of Breach Compensation as Profits in Lieu of Salary under Section 17(3)(iii)
Facts of the Case
Employment
Agreement: The Assessee (Respondent) entered into an
Employment Agreement with M/s. ACEE Enterprises ('ACEE') on January 10,
2007, to join as Chief Executive Officer (CEO)...