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PR. Commissioner of Income Tax vs. Bhadani Financiers Pvt. Ltd. & Connected Matters (Delhi High Court) – Section 153A, 68, 69C | No Addition Without Incriminating Material
Facts of the CaseThe present batch of appeals was filed by the Revenue under
Section 260A challenging the common order of the Income Tax Appellate Tribunal
(ITAT) for Assessment Years 2008-09, 2009-10, and 2010-1...
PR. Commissioner of Income Tax vs M/s Bhadani Financiers Pvt. Ltd. & Connected Matters (Delhi High Court) – Section 153A, 68, 69C of Income Tax Act | No Addition Without Incriminating Material
Facts of the CaseThe present batch of appeals was filed by the Revenue under
Section 260A of the Income Tax Act, 1961 challenging the common order passed by
the Income Tax Appellate Tribunal (ITAT) for Assessment...
PR. Commissioner of Income Tax vs Bhadani Financiers Pvt. Ltd. & Connected Matters (2021) – Section 153A, 68, 69C – No Addition Without Incriminating Material
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High Court
under Section 260A challenging the ITAT order for AYs 2008–09, 2009–10, and
2010–11.
The
Assessing Officer (AO) made a...
International Tractors Ltd. vs. Deputy Commissioner of Income Tax (LTU) & Anr. | Delhi High Court | Section 80JJAA & Prior Period Expenses Deduction
Facts of the
Case
The assessee, engaged in manufacturing tractors, filed its return
declaring taxable income without claiming:
Deduction under Section 80JJAA
Deduction for prior period expenses
...
Maruti Insurance Broking Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Deductibility of Business Expenditure Prior to License & “Setting Up of Business” under Section 3 & 260A of Income Tax Act, 1961
Facts of the
Case
The assessee company was incorporated on 24.11.2010 for
carrying insurance broking business.
Key preparatory steps were undertaken immediately:
Appointment of CEO and principal office...
Concentrix Services Netherlands B.V. & Optum Global Solutions International BV vs Income Tax Officer (TDS) & Anr. / Deputy Commissioner of Income Tax & Anr. (2021:DHC:1421-DB)
Facts of the
Case
Petitioners (Netherlands-based companies) held 99.99% shareholding
in Indian subsidiaries.
They applied under Section 197 of the Income Tax Act seeking
a lower withholding tax certific...
Concentrix Services Netherlands B.V. & Optum Global Solutions International B.V. vs Income Tax Officer (TDS) & Deputy Commissioner of Income Tax – Withholding Tax on Dividends under India–Netherlands DTAA (Delhi HC)
Facts of the
Case
The petitioners, Concentrix Services Netherlands B.V. and Optum
Global Solutions International B.V., are Netherlands-based entities
holding 99.99% shareholding in their respective Indian
...
Bharat Bhushan Jindal vs Principal Commissioner of Income Tax-12 & Anr (2021) – Eligibility under Vivad Se Vishwas Scheme when Appeal Restored via Section 254(2)
Facts of the CaseThe petitioner-assessee challenged the rejection of
Forms 1 and 2 filed under the Direct Tax Vivad Se Vishwas Act, 2020. The
Assessing Officer had significantly enhanced taxable income for AY 201...
Pr. Commissioner of Income Tax-8 vs Sony Mobile Communications India Pvt. Ltd. (Merged with Sony India Pvt. Ltd.) – Delhi High Court Judgment on Invalid Assessment of Non-Existent Entity under Sections 143(3), 144C & 292B
Facts of the
Case
The assessee company was engaged in import, sale, and distribution
of mobile phones and related services.
It entered into international transactions with Associated
Enterprises, leadin...
PR. COMMISSIONER OF INCOME TAX–8 vs SONY MOBILE COMMUNICATIONS INDIA PVT. LTD. (Delhi High Court) – Assessment on Non-Existent Entity, Validity under Sections 143(3), 144C & 292B of Income Tax Act
Facts of the
Case
The Respondent-Assessee, Sony Mobile Communications India Pvt.
Ltd., was engaged in importing, selling, and distributing mobile
phones in India and providing post-sale support services.
...