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PR Commissioner of Income Tax-6, New Delhi vs N.R. Portfolio Pvt. Ltd. (2019) – Doctrine of Merger, Finality & ITAT Rectification Powers under Sections 254(2), 154 & 147/148 Explained
Facts of
the Case
The
assessee (N.R. Portfolio Pvt. Ltd.) was subjected to reassessment
proceedings under Sections 147/148.
The
Assessing Officer made additions under Section 68.
CIT(A):...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd (2018) – Delhi High Court | Section 260A | Permanent Establishment & Royalty under India–Singapore DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A
challenging the taxability of income earned by Nortel Networks Singapore Pte
Ltd.The dispute primarily revolved around:
Whether the assessee had a Perman...
Principal Commissioner of Income Tax, Central-3 vs Abhisar Buildwell Pvt. Ltd. – No Addition under Section 153A Without Incriminating Material | Delhi High Court
Facts of the CaseA search operation was conducted on 21st January 2011 in the
Dharampal Satyapal Group. Consequent to the search, notice under Section 153A
was issued to the assessee, Abhisar Buildwell Pvt. Ltd., which...
Commissioner of Income Tax (International Taxation) vs Nortel Network Singapore Pte Ltd – No Permanent Establishment & Software Payment Not Royalty under India–Singapore DTAA (Section 260A, Income Tax Act, 1961)
Facts of the
CaseThe Revenue filed appeals before the Delhi High
Court under Section 260A of the Income Tax Act challenging the findings in
favor of Nortel Network Singapore Pte Ltd. The core dispute revolved around
...
Ashok Jaipuria vs Tejinder Kumar, ACIT (Income Tax Department) | Delhi High Court | Sections 276C(1) & 277 Income Tax Act | Additional Evidence in Criminal Prosecution
Facts of the Case
The
respondent (Income Tax Department) filed a complaint under Sections
276C(1) and 277 of the Income Tax Act regarding undisclosed foreign bank
accounts of the petitioner.
...
Pr. Commissioner of Income Tax (Central-3) vs Abhisar Buildwell Pvt. Ltd. – No Addition under Section 153A in Absence of Incriminating Material (Delhi High Court)
Facts of the CaseThe present matter arises from two appeals filed by the
Revenue against a common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Years 2007–08 and 2008–09. A search o...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd – No Permanent Establishment & Software Payments Not Royalty under India–Singapore DTAA (Delhi High Court)
Facts of the
CaseThe present appeals were filed by the Revenue under
Section 260A of the Income Tax Act, 1961 before the Delhi High Court. The
dispute pertained to the taxability of income earned by Nortel Networks
S...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd (2018) – Delhi High Court | Permanent Establishment & Royalty under India–Singapore DTAA
Facts of the
Case
The Revenue filed appeals under Section 260A challenging orders in
favour of the assessee, Nortel Networks Singapore Pte Ltd.
The dispute involved cross-border transactions and applicability...
PR. COMMISSIONER OF INCOME TAX (CENTRAL-3) vs ABHISAR BUILDWELL PVT. LTD. – Section 153A – No Addition Without Incriminating Material – Delhi High Court
Facts of the CaseA search operation was conducted on 21st January 2011 in the
Dharampal Satyapal Group. Consequent to the search, notice under Section 153A
was issued to the assessee, Abhisar Buildwell Pvt. Ltd., which...
M/s McKinsey Knowledge Centre India Pvt. Ltd. vs Pr. Commissioner of Income Tax, Delhi-6 (Delhi High Court, 2019) – KPO vs Knowledge Management Services & Precedential Value under Income Tax Law
Facts of the CaseThe assessee, M/s McKinsey Knowledge Centre India Pvt.
Ltd., filed appeals against orders passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2011–12 and 2012–13.The core disput...