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MSD Pharmaceuticals Pvt. Ltd. Vs. Additional Commissioner of Income Tax & Anr. | Delhi High Court on Transfer Pricing Adjustment under Section 92CA – AMP Expenditure and Bright Line Test (AY 2011-12)
Facts of the
CaseThe present appeals were filed by the assessee, MSD
Pharmaceuticals Pvt. Ltd., pertaining to Assessment Year 2011–2012, involving
transfer pricing adjustments in relation to Advertisement, Marketing...
M/s Televista Electronics Ltd. vs Dy. Commissioner of Income Tax | Appealability of Rectification Orders under Section 154 and Levy of Interest under Section 220(2) of the Income Tax Act, 1961 | Delhi High Court
Facts of the
CaseThe assessee, M/s Televista Electronics Ltd.,
filed its return for Assessment Year 1989–90 declaring income of Rs.
12,05,070/-. During the original assessment proceedings under Section 143(3),
the ...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT Order Set Aside for Non-Adjudication of Permanent Establishment (PE), Fees for Technical Services (FTS) and Attribution Issues under Sections 254(2) & 260A of the Income Tax Act, 1961
Facts of the
CaseThe assessee, GE Nuovo Pignone S.P.A., filed
appeals before the Delhi High Court under Section 260A challenging a common
order passed by the ITAT for Assessment Years 2001-02 to 2008-09.The grievance ...
Commissioner of Income Tax-II vs Mitsubishi Corporation India Pvt. Ltd. | Delhi High Court | Section 40(a)(i), Section 195, Section 260A of Income Tax Act | TDS on Payments to Non-Residents | DTAA Non-Discrimination Clause | Permanent Establishment (PE) Dispute
Facts of the CaseMitsubishi Corporation India Pvt. Ltd. was engaged
in international trade and procurement activities in India for the Mitsubishi
Group.For Assessment Year 2006-07:
The assessee filed its return decla...
H.T. Media Limited vs Principal Commissioner of Income Tax-IV, New Delhi Delhi High Court | ITA Nos. 548/2015 & 549/2015 | Assessment Year 2008–09 Section 14A read with Rule 8D of the Income-tax Act, 1961 – Disallowance of Expenditure in Relation to Exempt Income – Requirement of Recording Satisfaction by Assessing Officer
Facts of the CaseThe assessee, H.T. Media Limited, engaged in the
business of printing and publishing newspapers and periodicals, filed its
return for AY 2008–09 and claimed exempt dividend income amounting to ...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi-I | Delhi High Court on ITAT’s Failure to Adjudicate Installation PE, FTS Taxability and Attribution of Profits under Sections 260A & 254(2) of the Income Tax Act, 1961
Facts of the
CaseThe appellant-assessee, GE Nuovo Pignone S.P.A.,
filed appeals before the Delhi High Court challenging a common order passed by
the ITAT for Assessment Years 2001–02 to 2008–09. The grievance of t...
Pr. Commissioner of Income Tax-6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on Moratorium under Section 14 IBC and Continuation of Income Tax Appeals
Facts of the CaseThe Revenue Department filed multiple appeals
before the Delhi High Court challenging the order of the Income Tax Appellate
Tribunal (ITAT) concerning tax liability of Monnet Ispat & Energy Ltd.
D...
Tulsi Tracom Private Limited vs Commissioner of Income Tax–9 | Section 263 Revision Proceedings Quashed for Lack of Proper Opportunity of Hearing under Income Tax Act, 1961
Facts of the
CaseThe assessee, Tulsi Tracom Private Limited, engaged
in trading and investment in shares, filed its return for Assessment Year
2008–09 before the Income Tax Officer, Kolkata. The assessment was reope...
Kailash Nath & Associates vs Principal Commissioner of Income Tax (Delhi High Court) – Whether Agricultural Land Situated Beyond 8 KM from Jurisdictional Municipality but Within 8 KM of Another Municipality Constitutes a Capital Asset under Section 2(14) of the Income Tax Act, 1961
Facts of the
CaseThe assessee, Kailash Nath & Associates,
sold agricultural land situated in Kundli Village, Sonipat. During
assessment proceedings under Section 143(3), the Assessing Officer held that
the land w...
Woodward India Private Limited vs Additional Commissioner of Income Tax, Special Range-9, New Delhi | Delhi High Court | Refund of Income Tax with Interest under Section 244A(1A) of Income Tax Act
Facts of the CaseThe petitioner-company was entitled to income tax refunds for
Assessment Years 2005-06 and 2006-07 amounting to Rs. 51,85,752/- and Rs.
23,95,365/- respectively. The Income Tax Department had issued re...