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Landmark Rulings

All landmark rulings

21,440 rulings

  1. Direct Tax ·Supreme Court · 02 Mar 2023
    It is open for the Assessee to present its contention that it is recipient of benefit under Section 80G (5B) for a subsequent period (AY 2022-23 to 2026-27), before the CIT(E), when the matter is examined afresh.

    Sant Girdhar Anand Parmhans Sant Ashram Vs THE COMMISSIONER OF INCOME TAX

    (2023) TaxCorp(LJ) 31074 (SC) · Section 80G

  2. Direct Tax ·ITAT Delhi · 02 Mar 2023
    ITAT - The addition is deleted as the Assessing Officer bypassed the directions of the Dispute Resolution Panel (DRP) by rejecting the Assessee's books and invoking Section 40A(2).

    Technip Energies Italy S.P.A Vs DCIT

    (2023) TaxCorp(LJ) 31073 (ITAT-DELHI) · Section 40A(2)

  3. Direct Tax ·Calcutta High Court · 01 Mar 2023
    The compensation received by the Assessee on account of compulsory acquisition of land under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is exempt from the tax.

    The Durgapur Projects Limited Vs PRINCIPAL COMMISSIONER OF INCOME TAX

    (2023) TaxCorp(LJ) 31072 (HC-CALCUTTA) · Section 50C

  4. Direct Tax ·Madras High Court · 01 Mar 2023
    Toll roads and toll bridges are neither tangible nor intangible assets of the construction companies entering into concessionaire agreements with the Government.

    Naramada Infrastructure Construction Enterprises Limited Vs The Assistant Commissioner of Income Tax

    (2023) TaxCorp(LJ) 31071 (HC-MADRAS)

  5. Direct Tax ·ITAT Mumbai · 28 Feb 2023
    The receipt of shares of Dish TV as a gift is neither taxable under Section 56(1) absent the specific provisions to tax the same nor under Section 56(2)(viia) as the shares received are of a listed company.

    Direct Media Distribution Ventures Pvt. Ltd Vs The Assistant Commissioner of Income Tax

    (2023) TaxCorp(LJ) 31064 (ITAT-MUMBAI) · Sections 28(iv), 56

  6. Direct Tax ·Delhi High Court · 28 Feb 2023
    If CIT's order is adverse to the Assessee then it shall not be given effect to for two weeks from the date its receipt by the Assessee.

    OYO Hotels & Homes Pvt. Ltd Vs DEPUTY/ASSISTANT COMMISSIONER OF INCOME-TAX

    (2023) TaxCorp(LJ) 31063 (HC-DELHI)

  7. Direct Tax ·Delhi High Court · 28 Feb 2023
    The final assessment order passed under Section 143(3) r.w.s 144C in the name of non-existent company despite being diligently informed about the scheme of amalgamation, was invalid.

    Sony Mobile Communications India Pvt. Ltd Vs COMMISSIONER OF INCOME TAX

    (2023) TaxCorp(LJ) 31062 (HC-DELHI)

  8. Direct Tax ·ITAT Pune · 25 Feb 2023
    US entity's receipts from from an Indian IT Company towards provision of Cloud Services, Colocation and Network Services, Mainframe Services, Disaster/Data Recovery Services to be not taxable in India as Fees for Included Services.

    Sungard Availability Services LLP Vs ITO (IT)

    (2023) TaxCorp(LJ) 31049 (ITAT-PUNE)

  9. Direct Tax ·ITAT Delhi · 25 Feb 2023
    The advertisement and publicity expenditure incurred by the Assessee to increase awareness and popularity of Livpure brand cannot be said to have incurred wholly or exclusively for the purpose of business to claim it as revenue expenditure but have enduring benefits for indefinite period to treat it as capital expenditure.

    Livpure P Ltd Vs Addl. CIT

    (2023) TaxCorp(LJ) 31048 (ITAT-DELHI)

  10. Direct Tax ·ITAT Jaipur · 25 Feb 2023
    Addition of employee's contribution to the PF and ESI under Section 36(1)(va) through adjustment under Section 143(1) is not permissible.

    Paris Elysees India Private Limited Vs Deputy Commissioner of Income Tax

    (2023) TaxCorp(LJ) 31047 (ITAT-JAIPUR) · Section 143(1)

  11. Direct Tax ·ITAT Delhi · 25 Feb 2023
    In absence of specifications of the shares purchased by two persons in the sale deed, it must be held that both purchased equal shares.

    Shivani Madan Vs ACIT

    (2023) TaxCorp(LJ) 31046 (ITAT-DELHI)

  12. Direct Tax ·ITAT Mumbai · 25 Feb 2023
    DRP’s directions passed in contradiction to HC ruling in Assessee’s own case allowing DTAA benefit on interest income earned by Assessee, is not justified.

    Green Maiden A 2013 Trust Vs Assistant Commissioner of Income Tax

    (2023) TaxCorp(LJ) 31045 (ITAT-MUMBAI)

  13. Direct Tax ·ITAT Mumbai · 24 Feb 2023
    PCIT invoked Explanation 2(a) to Section 263 while passing the revisionary order but the Explanation was not invoked while issuing the notice.

    Sodexo India Services Private Limited Vs PCIT

    (2023) TaxCorp(LJ) 31037 (ITAT-MUMBAI)

  14. Direct Tax ·Allahabad High Court · 24 Feb 2023
    The reassessment notices issued to the petitioners in this bunch of writ petitions, on or after Apr 1, 2021 for AY 2013-14 to 2017-18 are to be dealt with, accordingly, by the Revenue.

    Rajeev Bansal & Ors Vs Union Of India And 3 Others

    (2023) TaxCorp(LJ) 31036 (HC-ALLAHABAD)

  15. Direct Tax ·ITAT Bangalore · 24 Feb 2023
    The amount paid by GIPL to the Assessee with reference to seconded employees does not come within the FIS under the Act or DTAA and the addition is liable to be deleted.

    Google LLC Vs JCIT (OSD) (IT), DCIT (IT)

    (2023) TaxCorp(LJ) 31035 (ITAT-BANGALORE)

  16. Direct Tax ·Madras High Court · 23 Feb 2023
    Search and seizure action, being highly intrusive in nature, must be conducted scrupulously in line with the parameters set out under the Statute and applicable Rules.

    Anil Jain Vs Principal Director General of Income Tax

    (2023) TaxCorp(LJ) 31033 (HC-MADRAS) · Sections 120, 132

  17. Direct Tax ·Delhi High Court · 21 Feb 2023
    The provisions of Section 254 are not applicable for adjudication of the application for recall of the order.

    CEMENT CORPORATION OF INDIA LTD Vs ASSISTANT COMMISSIONER INCOME TAX

    (2023) TaxCorp(LJ) 31026 (HC-DELHI)

  18. Direct Tax ·ITAT Delhi · 21 Feb 2023
    Fees received by Israeli company from its Indian subsidiary towards information technology and SAP support services is not in the nature of FTS under Article 13 of India-Israel DTAA due to non-fulfilment of make available condition.

    Netafim Ltd Vs DCIT

    (2023) TaxCorp(LJ) 31025 (ITAT-DELHI)

  19. Direct Tax ·Madras High Court · 20 Feb 2023
    The Assessee cannot contend that he was not afforded a personal hearing since he was granted several opportunities to respond to the notices under Section 142(1) and 143(2), which the Assessee failed to respond to.

    Suyambulingam Suresh Vs The Income Tax Officer

    (2023) TaxCorp(LJ) 31018 (HC-MADRAS)

  20. Direct Tax ·ITAT Mumbai · 18 Feb 2023
    Assessee has discharged its onus and the addition under Section 68 on account unexplained cash credit is liable to be deleted.

    Direct Logistics India Private Limited Vs Income Tax Officer

    (2023) TaxCorp(LJ) 31011 (ITAT-MUMBAI) · Section 68

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