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Reopening Quashed for Change of Opinion; Survey-Based Comparison with Subsequent Year Data Invalid – Matrix Clothing Pvt. Ltd. vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Matrix Clothing Private Limited, filed two
writ petitions challenging notices dated 31.03.2019 issued under Section 148 of
the Income-tax Act for Assessment Years 2014-15 and 2015-16 an...
Excess Cash Deposits Held Unexplained; No Substantial Question of Law under Section 260A – Kross Diamonds Pvt. Ltd. vs. ITO Ward 14(3) (Delhi HC)
Facts of the CaseThe assessee, Kross Diamonds Pvt. Ltd., filed appeals under
Section 260A of the Income-tax Act challenging a common order dated 18.12.2024
passed by the Income Tax Appellate Tribunal. The Tribunal had ...
Concurrent Jurisdiction of Jurisdictional AO and Faceless AO Reaffirmed; Reassessment Notices Upheld Despite Section 151A Challenge – Inder Dev Gupta vs. ACIT (Delhi HC)
Facts of the CaseA batch of writ petitions was filed by Inder Dev Gupta and connected
petitioners challenging notices issued under Section 148 of the Income-tax Act
by the Jurisdictional Assessing Officer of Central Ci...
Writ Petition challenging the retention of seized assets and seeking release of jewellery, cash and bullion seized during search proceedings KOSHALIYA DEVI RASTOGI Versus ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, NEW DELHI AND ANR
IN THE HIGH COURT OF DELHI AT NEW DELHIDate of Decision : 06.01.2026W.P.(C) 7448/2025 CM APPL. 41160/2025
KOSHALIYA DEVI RASTOGI
............................................PetitionerThrough: Mr. Sachit Jolly, Sr. Adv....
Reassessment Quashed as Time-Barred Where Notice Dispatched After Limitation Despite ITBA Generation Before Cut-Off – Grid Solutions SAS vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Grid Solutions SAS, filed a writ petition
challenging the notice dated 30.03.2025 issued under Section 148A(1) of the Income-tax
Act for Assessment Year 2019–20, the order dated 30.06...
Receipts from Off-the-Shelf Software, Bandwidth and IT Support Services Not Taxable as Royalty or FTS under India–Singapore DTAA; Revenue Appeals Dismissed – CIT (International Taxation) vs. DXC Technology Services Singapore (Delhi HC)
Facts of the CaseThe Revenue filed appeals under Section 260A of the Income-tax
Act challenging a common order dated 10.10.2023 passed by the Income Tax
Appellate Tribunal in respect of Assessment Years 2011-12 to 2014...
Reassessment for AY 2015–16 Quashed as Time-Barred; TOLA Inapplicable Post Rajeev Bansal – Anju Khosla vs. ITO Ward 15(1) (Delhi HC)
Facts of the CaseThe petitioner, Anju Khosla, challenged a notice dated
26.08.2024 issued under Section 148A(b) of the Income-tax Act for Assessment
Year 2015–16, the order dated 31.08.2024 passed under Section 148A(...
Reassessment Upheld Where No Change of Reasons and Section 148A Procedure Properly Followed Post-2022 Amendment – Amandeep Singh (Guru Kripa Enterprises) vs. ACIT (Delhi HC)
Facts of the CaseThe petitioner, Amandeep Singh, proprietor of Guru Kripa
Enterprises, filed his return of income for Assessment Year 2021–22 on
14.03.2022 declaring income of ₹8,53,950. On 29.03.2025, the Revenue ...
Jurisdiction of Jurisdictional Assessing Officer Upheld Despite Faceless Scheme; Reassessment Notices Sustained in Delhi – All India Kataria Educational Society vs. ACIT (Delhi HC)
Facts of the CaseA batch of writ petitions, including those filed by All India
Kataria Educational Society and connected assessees, were filed before the
Delhi High Court challenging notices issued under Section 148 of...
Invalid Remand by CIT(A) Set Aside Where Jurisdictional Defect under Section 143(2) Not Adjudicated; Matter Restored to CIT(A) – Akasaki Technology (P) Ltd. vs. PCIT (Delhi HC)
Facts of the CaseThe assessee, Akasaki Technology (P) Ltd., filed its return of
income for Assessment Year 2012–13 on 28.09.2012 declaring total income of
₹48,51,840. The assessment was reopened under Section 147 o...