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ITAT Delhi: Addition under Section 56(2)(viib) Cannot Be Made When Shares Are Valued Using DCF Method Supported by Valuation Report – ITO vs Kaka Services Pvt. Ltd.
Facts of the CaseThe assessee company, Kaka Services (P) Ltd., was engaged in
the business of financial services and was registered with the Reserve Bank of
India as a Non-Banking Financial Company (NBFC).The assessee ...
ACIT vs Verizon India Pvt. Ltd. – Penalty u/s 271(1)(c) Not Leviable Where Transfer Pricing Adjustment Arises from Bona Fide Difference in Comparables and Full Disclosure Made (ITAT Delhi)
Facts of the CaseThe assessee, Verizon India Pvt. Ltd., filed its return of
income along with a Transfer Pricing study report for its international
transactions with associated enterprises. The assessee adopted the
Tr...
Child Compassion Care India vs CIT(E) – ITAT Delhi Dismisses Appeal as Withdrawn | AY 2018-19 | Income Tax Appellate Tribunal Case Law
Facts of the CaseThe assessee, Child Compassion Care India, is a charitable
organization registered under the provisions of the Income-tax Act and engaged
in charitable activities. The organization claimed exemption un...
Ameriprise India Pvt. Ltd. vs ACIT – ITAT Delhi on Transfer Pricing Adjustment, Selection of Comparables and Treatment of Foreign Exchange Gain/Loss under Sections 92C & 92CA
Facts of the
CaseThe assessee,
Ameriprise India Pvt. Ltd., is a wholly owned subsidiary of Ameriprise USA,
engaged in providing Information Technology Enabled Services (ITES) and
back-office support services to its A...
DCIT vs Suruchi Foods Pvt. Ltd. – ITAT Delhi on Taxability of Keyman Insurance Policy Proceeds and Applicability of Section 10(10D) of the Income Tax Act
Facts of the
CaseThe dispute in the
present case arose in relation to the taxability of proceeds received from a
Keyman Insurance Policy originally taken by Suruchi Foods Pvt. Ltd. in the name
of its director.The com...
ITAT Delhi: CPC Cannot Make Adjustment Without Prior Intimation Under Section 143(1)(a) – Brahma Investments I Ltd. vs DCIT
Facts of the
CaseThe assessee, Brahma
Investments I Ltd., a tax resident of Cyprus, filed its return of income on 15.02.2021
declaring total income of ₹1,13,33,890. In the return, the assessee reported a long-term
...
Lex Sportel Vision Pvt. Ltd. vs ITO (ITAT Delhi) – Payment for Live Telecast Rights Not Taxable as Royalty u/s 9(1)(vi); No TDS Liability u/s 195 on “Live Rights”
Facts of the
CaseThe assessee, Lex
Sportel Vision Pvt. Ltd., is engaged in the business of acquiring and
sub-licensing broadcasting rights of various sports events such as cricket,
golf and football. For the Assessme...
ITAT Delhi: Taxation Must Be Based on Actual Income and Not on Hypothetical Computation – GSR Industries vs DDIT
Facts of the
CaseThe assessee, GSR
Industries, a partnership firm incorporated on 1 April 2010, filed its return
of income declaring its business results based on audited accounts. During the
assessment proceedings, ...
Assessment Order Without DIN is Invalid – ITAT Delhi Quashes Order in Gajendra Singh v. DCIT (ITA No. 1556/Del/2021) under Section 119 of the Income-tax Act
Facts of the
CaseThe assessee,
Gajendra Singh, filed appeals before the Income Tax Appellate Tribunal (ITAT),
Delhi Bench, against orders passed by the Commissioner of Income Tax (Appeals)
relating to Assessment Year...
ITAT Delhi: Deduction u/s 54 Allowed Even if New House Registered in Parents’ Name; Cost of Improvement for Residential Property Cannot Be Arbitrarily Disallowed – Rajiv Ghai vs ACIT
Facts of the
CaseThe assessee filed
his return of income declaring total income of ₹41,12,890. During the relevant
assessment year, the assessee sold a residential house situated at Rana Pratap
Marg, Lucknow for a ...