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Principal Commissioner of Income Tax-4, Delhi vs. Haier Appliances India Pvt. Ltd. (2022) – AMP Expenses and Transfer Pricing Adjustment under Income Tax Act
Facts of the CaseThe Revenue filed appeals challenging a common order passed
by the Income Tax Appellate Tribunal (ITAT) concerning Assessment Year 2011–12.
The dispute arose over whether routine selling and
distrib...
Uppal Chadha Hi-Tech Developers Pvt. Ltd. vs Income Tax Officer Ward 22(3), Delhi & Anr. (Delhi High Court, 2022) – Reassessment Invalid on Non-Existent Entity & Non-Reasoned Order under Sections 148A & 148
Facts of the Case
The
Petitioner challenged:
Show
cause notice dated 26.05.2022 under Section 148A(b)
Order
under Section 148A(d)
Notice
under Section 148 dated 30.05.2022
...
Vedanta Limited vs Assistant Commissioner of Income Tax & Anr. (Delhi High Court) – Remand by ITAT Set Aside; Scope of Tribunal Powers, Section 37, 115JB & 32(1)(iia) Explained
Facts of the CaseThe assessee, Vedanta Limited, filed an appeal challenging the
order passed by the Income Tax Appellate Tribunal (ITAT) concerning Assessment
Year 2014–15. The dispute arose from multiple additions a...
Commissioner of Income Tax (International Taxation)-2 vs NetApp B.V. (Delhi High Court) – No Interest under Section 234B When Income Assessed as NIL | ITA 338/2022
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 20th September 2021 passed by the Income Tax Appellate Tribunal
(ITAT) in ITA No. 1882/Del/2017 for Assessment Year 2013–14. Th...
Deputy Director of Income Tax (Investigation) Unit–4(3) v. Xiongwei Li (2022) – Delhi High Court on Look Out Circular (LOC) in Economic Offences
Facts of the Case
The
respondent, CEO of Huawei Telecommunications (India) Company Pvt. Ltd.,
was subjected to investigation following a search and seizure action
under Section 132 of the Income Tax A...
PR. Commissioner of Income Tax-1 vs Avery Dennison (India) Pvt. Ltd. (2022) – Delhi High Court | Transfer Pricing | Section 92B & 92F | Intra-Group Services & Outstanding Receivables
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 11.10.2021 passed by the Income Tax Appellate Tribunal (ITAT) for
Assessment Year 2009–10. The dispute primarily revolved aroun...
PR. Commissioner of Income Tax-1 vs M/s Attire Designers Pvt. Ltd. (2022) – Section 68 & Section 37(1) Additions Not Sustainable When Purchases Accepted | Delhi High Court
Facts of the CaseThe Revenue filed an appeal challenging the ITAT order which
upheld the deletion of additions made by the Assessing Officer under Section 68
and Section 37(1) of the Income Tax Act.The Assessing Office...
Commissioner of Income Tax (International Taxation)-2 vs. M/s Nagravision S.A. (Delhi High Court, 2022) – No Royalty on Supply of Software under Section 9(1)(vi) & India-Switzerland DTAA
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 31 January 2022 passed by the Income Tax Appellate Tribunal (ITAT)
for Assessment Year 2017–18. The dispute arose regarding the...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation (2022:DHC:3803-DB) – Transponder Charges Not Taxable as Royalty under Section 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue before the
Delhi High Court challenging the orders passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2014–15 and 2015–16. The cor...
Commissioner of Income Tax (International Taxation)-2 vs Intelsat Corporation | Delhi High Court (2022) – Transponder Charges Not Taxable as Royalty u/s 9(1)(vi)
Facts of the CaseThe present appeals were filed by the Revenue challenging
the orders passed by the Income Tax Appellate Tribunal (ITAT) for Assessment
Years 2014–15 and 2015–16. The dispute pertains to whether pay...