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Repair and Maintenance Services of Aircraft Equipment Do Not “Make Available” Technical Knowledge; Receipts Not Taxable as FTS/FIS under India–US DTAA – PCIT (International Taxation) vs. Goodrich Corporation (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the order dated 22.08.2024 passed by the
Income Tax Appellate Tribunal for Assessment Year 2018–19. The Tribunal...
Protective Additions Under Section 68 Not Sustainable Once Substantive Additions Made in Hands of Beneficiaries; Shell Conduit Cannot Be Taxed – PCIT, Delhi-7 vs. Third Generation Traders Pvt. Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed multiple appeals under Section
260A of the Income-tax Act, 1961 challenging a common order dated 20.09.2024
passed by the Income Tax Appellate Tribunal for Assessment Years 2012-13 to...
Addition on Alleged Bogus Purchases and Sales Leads to Double Taxation Where Income Already Offered; Section 145(3) Not Properly Invoked – PCIT (Central), Ludhiana vs. Garg Acrylics Ltd. (Delhi High Court)
Facts of the CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act, 1961 challenging the common order dated 27.10.2020 passed
by the Income Tax Appellate Tribunal for Assessment Year 2011–12. The T...
Form 26AS Mismatch Due to Apparent Errors Not “Tangible Material” for Reopening; Reassessment Based on Erroneous TDS Data Invalid – PCIT vs. Sanjay Pratap Singh (Delhi High Court)
Facts of the CaseThe assessee, Sanjay Pratap Singh, filed his
return of income for Assessment Year 2009–10 on 25.07.2009 declaring total
income of ₹10,92,498/-, comprising salary income and income from other source...
Reopening Beyond Four Years Invalid Without Allegation of Failure to Disclose Material Facts; Section 147 Jurisdiction Fails in Share Capital Case – PCIT vs. K.R. Pulp and Papers Ltd. (Delhi High Court)
Facts of the CaseThe assessee, M/s K.R. Pulp and Papers Ltd., a
public limited company engaged in manufacturing kraft and brown paper, filed
its return of income for Assessment Year 2009–10 on 26.09.2009 declaring in...
Reassessment Notice for AY 2013–14 Issued Beyond Residual Limitation under Section 149 Quashed; Computation Governed by Rajeev Bansal and Ram Balram Buildhome – Parveen Kumar Malhotra vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Parveen Kumar Malhotra, filed a
writ petition challenging the order dated 28.07.2022 passed under Section
148A(d) of the Income-tax Act, 1961 and the consequential notice dated
29.07.2...
TDS Credit Cannot Be Denied to NRI Seller for Deductor’s Use of Wrong Form; Revenue Directed to Correct Records and Grant Refund – Parag Keshav Bopardikar vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Parag Keshav Bopardikar, a
Non-Resident Indian and tax resident of the United States of America, filed a
writ petition challenging various communications and actions of the Income Tax
...
Refund Cannot Be Withheld Where Rectified Return Was Never Declared Invalid; Revenue Directed to Process Refund for AY 2016–17 – Mukesh Garg vs. ACIT (Delhi High Court)
Facts of the CaseThe petitioner, Mukesh Garg, filed a writ petition
seeking a direction to the Revenue to process his return of income for
Assessment Year 2016–17 and grant refund of ₹1,16,94,870/- along with statu...
Section 149(1)(c) Cannot Revive Time-Barred Reassessment Notices Even in Foreign Asset Cases; Notices Beyond Original Limitation Quashed – K.S. Dhingra vs. ACIT (Delhi High Court)
Facts of the CaseThe petitioner, K.S. Dhingra, filed writ petitions
challenging notices issued under Section 148 of the Income-tax Act, 1961
seeking to reopen concluded assessments for Assessment Years 1997–98 and
2...
Reassessment for AY 2013–14 Barred by Limitation Where Escaped Income Below ₹50 Lakhs; Section 148 Notice Quashed in Alleged Penny Stock Case – Manjeet Kaur Duggal vs. ITO (Delhi High Court)
Facts of the CaseThe petitioner, Manjeet Kaur Duggal, filed a writ
petition challenging the order dated 15.07.2022 passed under Section 148A(d) of
the Income-tax Act, 1961 and the consequential notice dated 15.07.2022 ...