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ITAT Delhi: No Profit Attribution to Alleged Dependent Agent PE When Indian AE Remunerated at Arm’s Length – Adobe Systems Software Ireland Ltd. vs ACIT
Facts of the CaseThe assessee, Adobe Systems Software Ireland Ltd., a tax
resident of Ireland, filed its return of income for Assessment Year 2016–17,
declaring income taxable at a special rate.During the assessment ...
ITAT Delhi: Penalty u/s 271D Not Leviable for Cash Advance Received Before Amendment to Section 269SS – Rajni Kant Jha vs ITO (ITA No. 446/Del/2023)
Facts of the CaseThe assessee, Rajni Kant Jha, sold an immovable property for a
total consideration of Rs. 28.10 lakhs. Out of this amount, Rs. 23.10 lakhs was
received in cash as advance in April 2015.The Assessing Of...
Transfer Pricing – Comparable Company Cannot Be Excluded Solely on Low Turnover if Functionally Similar | Ameriprise India Pvt. Ltd. vs ACIT (ITAT Delhi)
Facts of the CaseThe assessee, Ameriprise India Pvt. Ltd., is a wholly owned
subsidiary of Ameriprise USA, which is engaged in financial planning, asset
management, brokerage, and pension advisory services. The Indian ...
Advance Received on Agreement to Sell Agricultural Land Cannot Be Treated as Sale Consideration Without Transfer of Possession – ITAT Delhi in Mahesh Kumar vs ITO (AY 2014-15) | Section 2(47)
Facts of the CaseThe case was reopened by the Assessing Officer on the basis
that the assessee had deposited cash of ₹37,70,000 in his bank account during
Financial Year 2013-14 relevant to Assessment Year 2014-15.Du...
ITAT Delhi: Benefit of Section 11 Cannot Be Denied When Registration under Section 12AA Granted During Pending Assessment – Maa Bhagwati Charitable Trust vs ITO (ITA No. 2123/Del/2023)
Facts of the CaseThe assessee, Maa Bhagwati Charitable Trust, filed its return
of income for Assessment Year 2016-17 declaring Nil income. The case was
selected for scrutiny by the Assessing Officer (AO). The trust was...
Shree Gaushala, Sonipat vs ITO (Exemption) – ITAT Allows Section 11 Benefit for Charitable Trust Engaged in Gaushala Activities
Facts of the CaseThe assessee, Shree Gaushala, Sonipat, is a charitable
institution engaged in activities relating to the maintenance, protection, and
welfare of cows. The assessee claimed exemption under Section 11 of...
Ghibellines Security Solutions Ltd vs ACIT – ITAT Delhi on Addition for Unverified Transactions and Disallowance of Expenses under Sections 37(1) and 68
Facts of the CaseThe assessee, Ghibellines Security Solutions Ltd, is
engaged in providing security and facility management services. The company was
incorporated in 2004 and operates in the security services sector. F...
Puneet Kulthia vs ITO – ITAT Delhi | Reassessment u/s 147 Held Invalid Where Case Falls Under Section 153C – Addition u/s 68 Deleted
Facts of the CaseThe assessee, Shri Puneet Kulthia, filed his return of income
for the relevant assessment year declaring his income. The case was later
reopened by the Assessing Officer by issuing notice under Section...
Ajay Kumar Sharma vs ITO – ITAT Delhi Remands Share Valuation Dispute on FMV Determination under Rule 11UA for Capital Gains Computation (AY 2016-17)
Facts of the CaseThe assessee filed his return of income electronically on
28.02.2017 declaring total income of ₹12,68,070. The case was selected for
scrutiny assessment and statutory notices were issued. During asse...
ITAT Delhi: Exemption u/s 10(23C)(vi) for Educational Society – Assessment Set Aside Pending Decision on Exemption Application | S.D. Education Society vs ITO
Facts of the CaseThe assessee, S.D. Education Society, is an educational
society engaged in running educational institutions and claiming exemption
under Section 10(23C)(vi) of the Income Tax Act, 1961.For Assessment Y...