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Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (Delhi High Court, 2020) – Attribution of Profits to Permanent Establishment Restricted to 35%
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order passed by the Income Tax Appellate
Tribunal (ITAT) concerning Assessment Years 2004-05, 2006-07, 2007-08, and
...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (2020) – Delhi High Court | Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
Case
The appeals were filed by the Commissioner of Income Tax
(International Taxation)-3 against a common order of the ITAT dated
28.05.2019.
The dispute covered Assessment Years: 2004-05, ...
Commissioner of Income Tax – International Taxation–3 vs Rolls Royce PLC (Delhi High Court) – Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
CaseThe present appeals were filed by the Revenue
against a common order dated 28.05.2019 passed by the ITAT, New Delhi Bench,
concerning Assessment Years 2004-05, 2006-07, 2007-08, and 2009-10. The dispu...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (2020) – Delhi High Court | Attribution of Profits to Indian PE @ 35% Upheld
Facts of the
Case
The appeals were filed by the Commissioner of Income Tax
(International Taxation)-3 against a common order of the ITAT dated
28.05.2019.
The dispute covered Assessment Years: 2004-05, ...
Rajesh Khetarpal & Ors. vs Assistant Commissioner of Income Tax & Ors. | Delhi High Court | Reassessment Notices under Section 148 & Applicability of Amended Provisions Post Finance Act 2021
Facts of the
Case
Multiple writ petitions were filed challenging reassessment notices
issued after 1 April 2021 under the old provisions of Section 148.
The Finance Act, 2021 introduced a new reassessment reg...
Commissioner of Income Tax vs. M/s Prasidh Leasing Ltd. | Delhi High Court | Deemed Dividend under Section 2(22)(e) of Income Tax Act, 1961 | Trade Advance vs Loan Classification
Facts of the CaseThe assessee, M/s Prasidh Leasing Ltd., had shown M/s Ginza
Industries Ltd. as a sundry creditor in its books, with substantial funds
advanced by Ginza for the alleged procurement of import licenses. T...
Meera Gupta vs Deputy Commissioner of Income Tax & Ors. | Delhi High Court on Maintainability of Writ Petition Against Section 153A Assessment Order When Statutory Appeal is Already Filed
Facts of the CaseThe petitioner challenged assessment orders passed under Section
153A of the Income Tax Act, 1961 before the High Court through writ
petitions. Simultaneously, it was admitted before the Court that the...
Nimit Builders Pvt. Ltd. & Ors. vs Principal Commissioner of Income Tax–4 & Anr. | Delhi High Court on Issuance of Revised Form-3 under the Direct Tax Vivad Se Vishwas Act, 2020
Facts of the CaseThe petitioners had approached the Delhi High Court seeking
appropriate directions against the Income Tax Department concerning the
issuance of revised Form-3 under the Direct Tax Vivad Se Vishwas Sche...
Nimit Builders Pvt. Ltd. & Ors. vs Pr. Commissioner of Income Tax-4 & Anr. (Delhi High Court, 2021) – Writ Petitions Declared Infructuous Due to Issuance of Revised Form-3
Facts of the Case
Multiple
writ petitions were filed before the Delhi High Court by different
assessees raising similar grievances.
The
grievance primarily related to incorrect or disputed computat...
Nimit Builders Pvt. Ltd. & Ors. vs Pr. Commissioner of Income Tax-4 & Anr. (Delhi High Court, 2021) – Writ Petitions Disposed as Infructuous upon Issuance of Revised Form-3 under Income Tax Law
FACTS OF THE CASEMultiple writ petitions were filed by different petitioners
including Nimit Builders Private Limited and others before the Delhi High
Court. The petitions were directed against actions of the Principal...