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Payments for Off-the-Shelf Software Not Royalty under Indo-NZ DTAA; No TDS Obligation under Section 195 – CIT (IT)-3 vs. XIOCOM (NZ) Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 17.02.2022 passed by the
Income Tax Appellate Tribunal, whereby the ITAT dismissed the Revenue’...
No Permanent Establishment in India for Offshore Projects; Earlier Years Binding and No Stay by Supreme Court – CIT (IT)-2 vs. National Petroleum Construction Company (Delhi HC)
Facts of the
CaseThe Revenue filed three appeals under Section 260A
of the Income-tax Act, 1961 being ITA Nos. 361/2025, 362/2025 and 368/2025,
challenging the common order dated 22.06.2023 and the order dated 21.06.2...
Reopening Cannot Be Tested on Criminal Law Standards; ITAT Erred in Applying “Beyond Reasonable Doubt” Test to Section 148 – PCIT-1 vs. East Delhi Leasing Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 against the order dated 10.04.2024 passed by the
Income Tax Appellate Tribunal, whereby the ITAT dismissed the Revenue’s ap...
Section 40(a)(i) Disallowance Barred by DTAA Non-Discrimination Clause; No TDS Where Income Not Chargeable – PCIT-4 vs. Mitsubishi Corporation (India) Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed two appeals under Section 260A of
the Income-tax Act, 1961 being ITA Nos. 329/2025 and 332/2025, challenging the
common order dated 14.07.2022 passed by the Income Tax Appellate Trib...
Multiple Additions on Duties, Royalty, CSR, TP and Section 35(2AB) Covered by Earlier Years; No Substantial Question of Law – PCIT-4 vs. Maruti Suzuki India Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed two appeals under Section 260A of
the Income-tax Act, 1961 being ITA Nos. 321/2025 and 323/2025, challenging the
common order dated 09.02.2023 passed by the Income Tax Appellate Trib...
Section 40A(3) Disallowance Not Permissible Where Property Treated as Investment and Not Debited to P&L – PCIT (Central)-2 vs. Sanskar Homes Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 07.03.2019 passed by the
Income Tax Appellate Tribunal in ITA No. 4430/Del/2016 for Assessment Ye...
Notice under Section 153C for AY 2010–11 Held Time-Barred; Amendment to Section 153C Prospective; RRJ Securities Applied – PCIT-7 vs. Pragun Finance Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 30.05.2024 passed by the
Income Tax Appellate Tribunal in ITA No. 886/Del/2020 for Assessment Yea...
Penalty under Section 271E Barred by Limitation; Six-Month Period Runs from AO’s Initiation, Not JCIT Notice – PCIT-7 vs. Thapar Homes Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 27.11.2024 passed by the
Income Tax Appellate Tribunal, Delhi Bench ‘G’, for Assessment Year ...
Section 68 Addition on Share Capital Unsustainable Where Triple Test Satisfied; Concurrent Findings of Fact Not Interfered – PCIT (Central)-2 vs. BDR Builders & Developers Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 14.05.2024 passed by the
Income Tax Appellate Tribunal for Assessment Years 2016–17 and 2018–...
Demonetisation Cash Deposits Explained Through Regular Cash Withdrawals and Prior Cash Balances; No Substantial Question of Law – PCIT (Central) Gurugram vs. Pancham Realcon Pvt. Ltd. (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 07.11.2023 passed by the
Income Tax Appellate Tribunal, Delhi Bench, which dismissed the Revenue...