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Principal Commissioner of Income Tax, Delhi-2 vs Best Infrastructure (India) Pvt. Ltd. & Connected Matters (Delhi High Court) – Addition under Section 68 and Scope of Assessment under Section 153A of Income Tax Act, 1961 on the Basis of Search Statements and Alleged Incriminating Material
Facts of the CaseA search and seizure operation was conducted
against the Best Group of Companies and one Tarun Goyal on 15 September 2008.During the course of search:
Loose papers and documents were seized.
The Re...
Principal Commissioner of Income Tax-7 vs Paramount Biotech Industries Ltd. | Mandatory Notice under Section 143(2) in Reassessment Proceedings under Sections 147/148 of the Income Tax Act
Facts of the CaseThe Revenue challenged the order of the Income Tax
Appellate Tribunal (ITAT) for Assessment Years 1999-2000 and 2000-2001. The
dispute arose from reassessment proceedings initiated by the Assessing Off...
Principal Commissioner of Income Tax-7 vs M/s Paramount Biotech Industries Ltd. | Mandatory Notice under Section 143(2) in Reassessment Proceedings under Sections 147/148 – Delhi High Court
Facts of the CaseThe Revenue filed appeals against the order of the
Income Tax Appellate Tribunal relating to Assessment Years 1999–2000 and
2000–2001. The reassessment proceedings were initiated on the ground that...
Principal Commissioner of Income Tax, Delhi-2 vs Best Infrastructure (India) Pvt. Ltd. & Connected Group Cases: Whether Statement Recorded under Section 132(4) Alone Constitutes Incriminating Material for Section 153A Assessment and Addition under Section 68 of the Income Tax Act
Facts of the
CaseA search and seizure operation under Section 132
was conducted on 15 September 2008 against the Best Group and one Tarun Goyal.During the search:
Certain loose papers/documents were seized.
Revenu...
Bently Nevada LLC vs Commissioner of Income Tax (International Taxation), Delhi-I | Delhi High Court | Remand on Taxability of Software Income and Attribution of Hardware & Software Revenue under Section 260A of the Income-tax Act, 1961
Facts of the CaseBently Nevada LLC filed appeals before the Delhi
High Court challenging the order of the Income Tax Appellate Tribunal dated
27.01.2017. The grievance of the appellant was that although several
substa...
Principal Commissioner of Income Tax (Central)-2 vs Index Securities Pvt. Ltd. & Vidya Shankar Investment Pvt. Ltd. | Delhi High Court | Scope of Section 153C – Seized Documents Must “Belong To” Assessee and Be Incriminating for Relevant Assessment Years
Facts of the
CaseA search and seizure operation under Section 132
was conducted on the Jagat Group and its associated entities. During the course
of the search, certain trial balances and balance sheets relating to In...
Bently Nevada LLC vs Commissioner of Income Tax (International Taxation), Delhi-I | Delhi High Court | Remand on Taxability of Software Income and Attribution Between Hardware, Software and Services under Section 260A of the Income-tax Act, 1961
Facts of the CaseBently Nevada LLC preferred a batch of appeals
before the Delhi High Court against the order passed by the Income Tax
Appellate Tribunal. The Tribunal had dismissed the appellant’s appeals without
r...
Principal Commissioner of Income Tax (Central)-2 vs Index Securities Pvt. Ltd. & Vidya Shankar Investment Pvt. Ltd. | Delhi High Court | Scope of Section 153C for Non-Incriminating Seized Documents
Facts of the
CaseThe Income Tax Department conducted a search and
seizure operation under Section 132 on the Jagat Group and its associated
persons. During the search, certain financial documents, including trial
bal...
Bently Nevada LLC vs Commissioner of Income Tax (International Taxation), Delhi-I | Delhi High Court on Taxability of Software Income and Attribution between Hardware, Software Sales & Services under Section 260A of the Income-tax Act, 1961
Facts of the CaseBently Nevada LLC filed multiple appeals under
Section 260A of the Income-tax Act against the order of the Income Tax
Appellate Tribunal dated 27.01.2017. The grievance raised by the appellant was
tha...
Principal Commissioner of Income Tax (Central)-2 vs Index Securities Private Limited & Vidhya Shankar Investment Pvt. Ltd. | Delhi High Court | Scope of Section 153C Proceedings in Absence of Incriminating Material
Facts of the
CaseA search and seizure operation under Section 132
was conducted by the Income Tax Department on Jagat Group and associated
entities on 14 September 2010. During the course of search, certain documents
...