Blog Categories
Subscribe to Newsletter
Join our subscribers list to get the latest Tax Updates and Opportunities.
Commissioner of Income Tax (International Taxation)-3 vs Ricardo U.K. Limited – No Further Profit Attribution to PE When Arm’s Length Remuneration Paid [Section 9, India-UK DTAA]
Facts of the
CaseThe case pertains to Assessment Year 2016–17. The
respondent, Ricardo U.K. Limited, is a company incorporated in the United
Kingdom and is a tax resident of the UK under Article 4 of the India-UK Do...
Deepak Modi vs Assistant Commissioner of Income Tax Circle 46(1) & Anr. | Delhi High Court | Reassessment u/s 148A(d) Set Aside for Violation of Natural Justice (No Personal Hearing)
Facts of the
CaseThe present writ petition pertains to Assessment
Year 2019–2020, wherein the petitioner, Deepak Modi, was subjected to
reassessment proceedings on allegations of availing accommodation entries
thro...
Shourya Estates Pvt. Ltd. vs Income Tax Officer, Ward 23(2), New Delhi & Anr. (Delhi High Court) – Reopening of Assessment under Section 148 Quashed
Facts of the
CaseThe present writ petition pertains to Assessment
Year (AY) 2011–12. The petitioner, Shourya Estates Pvt. Ltd. (SEPL), challenged
the legality of a notice dated 31.03.2018 issued under Section 148 of...
Intertek India Private Limited vs Income Tax Officer, Ward International Taxation (Delhi High Court, 2023) – Section 201 & 195 Income Tax Act | TDS on Management Fees
Facts of the
CaseThe petitioner, Intertek India Private Limited,
challenged:
Notice dated 10.10.2017 issued under Section 201 of the Income-tax
Act, 1961, and
Order dated 25.03.2021 rejecting objections agai...
M/s FIS Payment Solutions & Services India Pvt. Ltd. vs Deputy Commissioner of Income Tax-9(1) & Anr. (Delhi High Court, 2023)
Facts of the
CaseThe petitioner, M/s FIS Payment Solutions &
Services India Pvt. Ltd., filed a writ petition seeking release of a refund
amounting to ₹62.14 crores under Section 143(1) of the Income-tax Act, 196...
PR. Commissioner of Income Tax-04, Delhi vs M/s Inductis India Pvt. Ltd. – No Disallowance u/s 14A & No TP Adjustment on Receivables for Debt-Free Company | Delhi High Court
Facts of the
CaseThe assessee, a wholly owned subsidiary engaged in
IT-enabled back-office and analytics services, filed its return declaring
income of ₹16.42 crores. The case was selected for scrutiny and proceedin...
PR Commissioner of Income Tax–Delhi-04 vs Nikon Systems Pvt. Ltd. (Delhi High Court) – Allowability of Fire Loss as Revenue Loss u/s 28 & Taxability u/s 41(1) of Income Tax Act
Facts of the
CaseThe respondent/assessee, Nikon Systems Pvt. Ltd.,
was engaged in manufacturing, trading, and export of goods including
electronics and home furnishing items.During the relevant assessment year, a fire...
Tirupati Buildings and Offices Pvt. Ltd. vs Commissioner of Income Tax & Anr. | Delhi High Court | Refund Adjustment & Stay of Demand under Income Tax Law
Facts of the
CaseThe petitioner, Tirupati Buildings and Offices
Private Limited, sought release of a refund amounting to ₹87,89,440 for
Assessment Year (AY) 2018–19, which had been adjusted by the revenue
authori...
Pr. Commissioner of Income Tax, Delhi-1 vs M/s Blackroak Securities Pvt. Ltd. – Penalty u/s 271(1)(c) Invalid Without Specifying Limb (Delhi High Court)\
Facts of the
CaseThe present appeal pertains to Assessment Year
2014–15, wherein the Revenue challenged the order passed by the Income Tax
Appellate Tribunal (ITAT) dated 05.05.2020.The ITAT had set aside the order ...
Syed Habeebur Rehman vs Deputy Commissioner of Income Tax Circle 28(1) & Ors. – Refund Adjustment Without Notice under Section 245 of Income Tax Act
Facts of the
CaseThe petitioner, Syed Habeebur Rehman, filed
a writ petition seeking issuance of directions to the Income Tax Department for
refund of approximately ₹46 lakhs relating to Assessment Years (AY) 2010â€...