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Pyramid IT Consulting Pvt. Ltd. vs Additional Commissioner of Income Tax | Delhi High Court on Transfer Pricing Adjustment, Functional Comparability and Selection of Comparable Companies under Sections 92C & 254(2) of the Income-tax Act, 1961
Facts of the CaseThe
assessee, Pyramid IT Consulting Pvt. Ltd., was engaged in providing value-added
IT solutions and IT staffing services to global entities. For Assessment Year
2010-11, the assessee filed its return...
PR. Commissioner of Income Tax-6, New Delhi vs McDonald’s India Pvt. Ltd. (Delhi High Court) – Section 14A Disallowance Not Applicable in Absence of Exempt Income [AY 2008-09]
Facts of the CaseThe Revenue filed
an appeal under Section 260A challenging the order of the Income Tax Appellate
Tribunal (ITAT) for Assessment Year 2008-09. The Assessing Officer had made a
disallowance of ₹1,64,4...
Commissioner of Income Tax (LTU) vs Honda Cars India Ltd. (2019) – Royalty & Technical Knowhow Payments Held as Revenue Expenditure under Income Tax Act
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the order of the Income Tax Appellate Tribunal
(ITAT) for Assessment Year 2010–11. The core dispute revolved around mu...
Kalanithi Maran vs Income Tax Officer (ITO) through Assistant Commissioner of Income Tax | Delhi High Court | Withdrawal of Petition Challenging Sanction for Prosecution (Sections 22 & 23 Context)
Facts of the
CaseThe petitioner, Kalanithi Maran, filed criminal miscellaneous petitions before the
Delhi High Court challenging proceedings initiated by the Income Tax
Department. The challenge primarily related to t...
Kalanithi Maran vs Income Tax Office (ITO) through Assistant Commissioner of Income Tax | Delhi High Court | Sections 22 & 23 – Challenge to Validity of Sanction for Prosecution
Facts of the
CaseThe petitioner, Kalanithi Maran, filed petitions
before the Delhi High Court challenging criminal proceedings initiated by the
Income Tax Department. The proceedings were based on sanctions granted fo...
PR. Commissioner of Income Tax, Delhi-2 vs Blue Scope Steel India Pvt. Ltd. (2019) – Delhi High Court | Transfer Pricing | Section 92CA & 260A | Salary Reimbursement to AE
Facts of the Case
The
assessee, Blue Scope Steel India Pvt. Ltd., is a subsidiary of an
Australian company engaged in providing business support services.
Due
to operational constraints, a Joint Ve...
Manish Periwal vs Assistant Commissioner of Income Tax & Anr. | Directorate of Enforcement (2019:DHC:7616) – Withdrawal of Petitions & Admissibility of Documents under Criminal Proceedings
Facts of the Case
The
petitioner, Manish Periwal, challenged an order dated 28.11.2017
passed by the Additional Sessions Judge in Criminal Revision No. 225/2017.
The
revision petition had que...
Toshiba India Pvt. Ltd. vs Deputy Commissioner of Income Tax & Assistant Commissioner of Income Tax (Delhi High Court) – Deduction of Interest on Customs Duty under Section 43B of Income Tax Act
Facts of the CaseThe assessee, Toshiba India Pvt. Ltd., filed two appeals
before the Delhi High Court against orders of the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Years (AY) 2012–13 and 2013–14....
M/s Infonox Software Pvt. Ltd. & Ors. vs Deputy Commissioner of Income Tax (Delhi High Court, 2019) – Withdrawal of Criminal Petitions under Section 139(1) Income Tax Act
Facts of the CaseThe petitioners, M/s Infonox Software Pvt. Ltd. and others,
filed multiple criminal miscellaneous petitions before the Delhi High Court
seeking relief against proceedings initiated by the Deputy ...
M/s Kolahai Infotech Pvt. Ltd. vs Income Tax Officer (2018) – Reassessment Quashed Due to Incorrect “Reasons to Believe” under Sections 147/148 of Income Tax Act
Facts of the
CaseThe petitioner company challenged a reassessment
notice issued under Sections 147 and 148 of the Income Tax Act. The notice was
based on information received from a survey conducted under Section 133A...