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ITAT Order Set Aside for Lack of Reasoned Findings on Transfer Pricing Comparables; Matter Remanded for Fresh Adjudication – TPG Software Pvt. Ltd. vs. DCIT (Delhi High Court)
Facts of the
CaseThe assessee, TPG
Software Pvt. Ltd., filed an appeal under Section 260A of the Income-tax Act,
1961 challenging the order dated 11.09.2023 passed by the Income Tax Appellate
Tribunal in ITA No. 6468...
Prosecution under Section 276CC Cannot Be Sustained in Absence of Wilful Default; Mens Rea Not Established Despite Service of Section 153A Notice – PCIT (Central-1) vs. Prabodh Kumar Tiwari (Delhi High Court)
Facts of the
CaseThe Revenue filed
multiple criminal leave petitions under Sections 378(2)(b) and 378(3) of the
Code of Criminal Procedure challenging a common order of acquittal passed by
the Appellate Court for Ass...
Prosecution under Section 276CC Fails in Absence of Wilful Default Despite Service of Section 153A Notice; Acquittal Upheld on Merits – PCIT vs. Prabodh Kumar Tiwari (Delhi High Court)
Facts of the
CaseThe Revenue filed
multiple criminal leave petitions under Sections 378(2)(b) and 378(3) of the
Code of Criminal Procedure challenging a common order of acquittal passed by
the Appellate Court in resp...
Reassessment for AY 2014–15 Reconsidered in Light of Rajeev Bansal; Matter Remanded to AO to Examine Limitation Afresh – Swadeshi Tubes Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Swadeshi Tubes Ltd., filed a writ petition relating to Assessment Year 2014–15
challenging the foundational notice dated 29.06.2021 issued under Section 148
of the Income-tax Act, 1...
Addition under Section 68 Unsustainable Where Assessee Did Not Transfer Property and Alleged Undervaluation Arose Only from Share Transfers Between Shareholders; ITAT Remand Set Aside – Snerea Properties Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe assessee,
Snerea Properties Pvt. Ltd., filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 19.01.2025 passed by the
Income Tax Appellate Tribunal in ITA No....
Addition under Section 68 Not Sustainable Where No Transfer of Property by Assessee and Transaction Involves Share Transfer Between Shareholders; ITAT Remand Set Aside – Shrey Properties Pvt. Ltd. vs. ACIT (Delhi High Court)
Facts of the
CaseThe assessee,
Shrey Properties Pvt. Ltd., filed an appeal under Section 260A of the
Income-tax Act, 1961 challenging the order dated 19.01.2025 passed by the
Income Tax Appellate Tribunal in ITA No. ...
Notice under Section 148 for AY 2014–15 Barred by Limitation Where Ten-Year Block under Section 153A Excludes Relevant Year; Search-Based Reopening Quashed – Shashank Gupta vs. ACIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Shashank Gupta, filed a writ petition challenging the notice dated 25.03.2025
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2014–15 and the proceedings in...
Section 148 Notice for AY 2016–17 Time-Barred under First Proviso to Section 149; Limitation Not Extended by Earlier Litigation – Sanjay Bansal vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Sanjay Bansal, filed a writ petition challenging the notice dated 15.04.2024
issued under Section 148 of the Income-tax Act, 1961 for Assessment Year
2016–17. The impugned notice wa...
Reassessment Initiated During Pending Scrutiny Assessment Is Without Jurisdiction; Parallel Proceedings under Sections 147 and 143(3) Impermissible – Salesforce.com Singapore Pte. Ltd. vs. DCIT (Delhi High Court)
Facts of the
CaseThe petitioner,
Salesforce.com Singapore Pte. Ltd., filed a writ petition challenging the
assessment order dated 21.01.2025 passed under Section 147 read with Section
144C(13) of the Income-tax Act, ...
Reassessment Notice for AY 2015–16 Issued After 1 April 2021 Is Time-Barred; Proceedings Quashed Following Rajeev Bansal – Roopa Goyal vs. ITO (Delhi High Court)
Facts of the
CaseThe petitioner,
Roopa Goyal, filed a writ petition challenging the initial notice dated
23.06.2021 issued under Section 148 of the Income-tax Act, 1961, subsequent
notices dated 31.05.2022, the order...