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Commissioner of Income Tax (Exemption), New Delhi vs U.P. Distillers Association (Delhi High Court, 2019) – Invalidity of Section 153A Assessment Without Search & Evidentiary Value of Loose Papers
Facts of the CaseThe Revenue conducted a search and seizure operation under
Section 132 of the Income Tax Act at the residence of the Secretary General of
the assessee association and collected documents allegedly indi...
Commissioner of Income Tax vs. Kohinoor Foods Limited (2019) – Scope of Revision under Section 263 of Income Tax Act | No Error Without Proper Finding
Facts of the
Case
The assessee, Kohinoor Foods Ltd., was engaged in manufacturing and
trading of rice.
Assessments for AY 1999–2000, 2000–2001, and 2001–2002 were
completed under Section 143...
Principal Commissioner of Income Tax, Delhi-2 vs MLS CBRE South Asia Pvt. Ltd. | Section 36(1)(ii) Disallowance on Director’s Commission – Delhi High Court (2020)
Facts of the CaseThe respondent-assessee, a private limited company, filed
its return declaring substantial income for AY 2009–10. During assessment under
Section 143(3), the Assessing Officer made a disallowance of ...
M/s JBM Industries Ltd vs Commissioner of Income Tax, New Delhi (Delhi High Court) – Disallowance of Foreign Education Expenses under Section 37(1) of the Income Tax Act
Facts of the Case
The
assessee company claimed deduction of substantial expenditure incurred on
foreign education (MBA at Boston University, USA) of Ms. Esha Arya,
daughter of one of its Directors.
...
Commissioner of Income Tax vs. Kohinoor Foods Limited (2019) – Section 263 Revision | Suppression of Sales & Assessment Inquiry Dispute
Facts of the
CaseThe assessee, Kohinoor Foods Limited, engaged in
manufacturing and trading of rice, filed returns for AYs 1999–2000, 2000–2001,
and 2001–2002, which were scrutinized and assessed under Sec...
M/s JBM Industries Ltd. vs Commissioner of Income Tax, New Delhi (Delhi High Court, 2019) – Disallowance of Foreign Education Expenses under Section 37(1) of the Income Tax Act
Facts of the CaseThe assessee, M/s JBM Industries Ltd., claimed
deduction of expenses incurred towards the foreign education of Ms. Esha Arya,
daughter of one of its Directors, for Assessment Years 2001–02 to 2004–...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax | Delhi High Court Judgment on ITAT Remand Powers & Permanent Establishment (PE) Issue [Sections 147/148]
Facts of the Case
The
appellant, LG Electronics Inc., Korea, challenged orders of the ITAT
concerning multiple assessment years.
The
central dispute revolved around whether the appellant had a Perm...
PR. Commissioner of Income Tax-7 vs Royal and Sun Alliances IT Solutions (India) Pvt. Ltd. (2019) – Penalty u/s 271(1)(c) on Transfer Pricing Adjustment Held Unsustainable (Delhi High Court)
Facts of the
CaseThe Revenue filed an appeal under Section 260A
of the Income Tax Act, 1961 challenging the order of the Income Tax
Appellate Tribunal (ITAT), which had set aside the penalty imposed under Sectio...
M/s JBM Industries Ltd. vs Commissioner of Income Tax, New Delhi (Delhi High Court) – Disallowance of Foreign Education Expenses under Section 37(1) of the Income Tax Act
Facts of the Case
The
assessee company incurred expenses towards foreign education (MBA at
Boston University, USA) of Ms. Esha Arya, daughter of one of its Directors.
The
expenditure claimed ...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court, 2020) – ITAT Remand to DRP Set Aside on Permanent Establishment Issue under Sections 147/148
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged
the order of the Income Tax Appellate Tribunal (ITAT), which had remanded
multiple appeals back to the Dispute Resolution Panel (DRP). The remand w...