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Commissioner of Income Tax (International Taxation)-2, Delhi vs LG Philips Display Korea Co. Ltd & Ors. | Delhi High Court | Section 9(1)(i), Section 147 Income Tax Act | Permanent Establishment & Income Attribution
Facts of the CaseThe present appeals were filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT), which had dismissed the
Revenue’s appeals and allowed the cross-objections of the asse...
Commissioner of Income Tax (International Taxation)-2, Delhi vs LG Philips Display Korea Co. Ltd & Ors (2021:DHC:3050-DB) – No PE in India & No Substantial Question of Law under Section 147
Facts of the CaseThe present appeals were filed by the Revenue challenging the
order dated 20 October 2020 passed by the Income Tax Appellate Tribunal (ITAT).
The ITAT had dismissed the appeals filed by the Revenue and...
Commissioner of Income Tax (International Taxation)-2, Delhi vs LG Philips Display Korea Co. Ltd & Ors | Delhi High Court | Section 9(1)(i), Section 147, DTAA (Permanent Establishment)
Facts of the CaseThe present appeals were filed by the Revenue before the Delhi
High Court challenging the order dated 20th October 2020 passed by the Income
Tax Appellate Tribunal (ITAT). The Tribunal had dismissed th...
Paramount Residency Private Limited vs Deputy Commissioner of Income Tax & Anr. (Delhi High Court) – Section 68 Addition, Remand for Fresh Adjudication on Merits
Facts of the CaseThe present appeal was filed by the appellant, Paramount
Residency Private Limited, challenging the order dated 11th December 2020
passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Year...
Late Sh. Ram Avtar Bhageria (Through LRs) vs Assistant Commissioner of Income Tax Circle 61(1), New Delhi & Anr. (2021) – Invalid Reassessment Notice Issued in Name of Deceased Assessee u/s 148 Income Tax Act
Facts of the CaseThe present writ petition was filed challenging a reassessment
notice dated 24 June 2021 issued under Section 148 of the Income Tax Act, 1961
in the name of Late Shri Ram Avtar Bhageria for Assessment ...
Ramtech Consulting vs National E-Assessment Centre & Ors. (Delhi High Court, 2021) – Violation of Natural Justice under Section 144B of Income Tax Act
Facts of the
CaseThe petitioner challenged the draft assessment
order dated 25 March 2021 and the final assessment order dated 24 May
2021 for Assessment Year 2017–18. The impugned orders were passed under
Sections...
Commissioner of Income Tax (Exemptions), Delhi vs Association of State Road Transport Undertakings (Delhi High Court, 2021) – Charitable Purpose under Section 2(15) despite Commercial Receipts
Facts of the CaseThe present appeal was filed by the Commissioner of Income Tax
(Exemptions), Delhi challenging the order dated 25 February 2020 passed by the
Income Tax Appellate Tribunal (ITAT), wherein the appeal of...
BT (India) Private Limited vs Income Tax Officer & Anr. (Delhi High Court, 2021) – Jurisdiction under Section 201 & TDS on Payments to Non-Residents
Facts of the CaseThe petitioner, BT (India) Private Limited, filed multiple
writ petitions challenging a common order dated 26.08.2021 and the issuance of
show cause notices under Sections 201(1) and 201(1A) of the Inc...
Mrs. Sripathi Subbaraya Manohara (Legal Heir of Late Sripathi Subbaraya Gupta) vs Principal Commissioner of Income Tax-22, New Delhi & Anr. (2021) – Invalidity of Reassessment Notice Issued to Deceased Assessee under Sections 147/148 of Income Tax Act
Facts of the
Case
The Income Tax Department issued a notice dated 22.03.2019 under
Section 148 for reopening assessment for AY 2012-13.
Subsequently, assessment order dated 14.11.2019 and penalty
notice...
BT (India) Private Limited vs Income Tax Officer & Anr. (Delhi High Court, 2021) – Challenge to TDS Liability under Sections 201(1) & 201(1A) of Income Tax Act
Facts of the Case
The
petitioner, BT (India) Private Limited, made payments to its foreign
entity, BT Plc (UK), for telecommunication and support services.
A
survey under Section 133A was conducted...