Income Tax – Reassessment Proceedings – Validity of Sanction – Batch of writ petitions challenging reassessment action initiated by the Income Tax Department under Section 148 of the Income Tax Act, 1961 for AY 2015-16 – Petitioners argue that reassessment notices were issued without proper sanction from the Principal Chief Commissioner/Chief Commissioner/Principal Commissi...
Income Tax – Infrastructure Development – Eligibility for Deduction under Section 80IA(4) – The respondent, engaged in infrastructure development at Kakinada Deep Water Port, claimed a deduction under Section 80IA(4) of the Income Tax Act for the development of a Mechanised Port Handling System – The revenue disallowed the deduction, contending that the respondent had no di...
Taxation Law – Reassessment under Income Tax Act – Issuance of Notice to Deceased Person – Petitioner, the legal heir of late Sh. Vijay Shankar Goel, challenged the reassessment notice under Section 148A(b) and subsequent order under Section 148A(d) – Notices were issued in the name of the deceased assessee despite the department being informed about his death – Held:...
Facts:
The petitioner, Skill Lotto Solutions Pvt. Ltd., filed a writ petition alleging violation of Article 14 and impugning the definition of 'goods' under Section 2(52) of the Central Goods and Services Tax Act, 2017. The petitioner contested the inclusion of actionable claim in the definition and argued that it was contrary to the legal meaning of goods and unconstitutional. The peti...
Facts:
PILCOM, a committee formed by Cricket Control Boards/Associations of Pakistan, India, and Sri Lanka for conducting the World Cup tournament in 1996, made payments to ICC and various Cricket Control Boards/Associations of member countries from its London Bank Accounts. The Income Tax Officer issued a show cause notice under Section 194E of the Income Tax Act, 1961, questioning whether in...
Facts:
The case pertains to the interpretation of Sections 143(1) and 143(2) of the Income Tax Act, 1961. The appellant, Vodafone Idea Ltd., filed a return of income for Assessment Year (AY) 2017-18. Subsequently, a notice was issued under Section 143(2) of the Act, initiating proceedings for scrutiny assessment.
Issues:
The distinction between the exercise of power under S...
Facts:
The case involves the supply of pipes and measurement equipment (SKID equipment) by the respondent (M/S. Adani Gas Ltd.) to its industrial, commercial, and domestic consumers under the head of 'gas connection charges'. The respondent considered this supply as a service related to 'tangible goods' for the consumers' use without transferring the right of possession and...
The respondent, a company incorporated in the UAE, provided remittance services and established liaison offices in India. These offices were primarily engaged in downloading remittance information and printing cheques/drafts for delivery to beneficiaries in India based on instructions from NRI remitters. The RBI granted permission for these offices to engage in specific activities.
Is...
Facts:
The case involves a challenge to the constitutional validity of Section 43B(f) of the Income Tax Act, 1961, as inserted by the Finance Act, 2001. The provision pertains to the deduction for liability under the leave encashment scheme.
Issues:
Whether the newly inserted Clause (f) to Section 43B of the Income Tax Act, 1961, is constitutionally valid?
Whether the absence ...
FACTS:
Yum! Restaurants (Marketing) Private Limited (YRMPL), a fully-owned subsidiary of Yum! Restaurants (India) Private Limited (YRIPL), was incorporated to undertake Advertising, Marketing, and Promotion (AMP) activities for YRIPL and its franchisees. YRMPL received contributions from both members (franchisees) and non-members (Pepsi Foods Ltd.). YRMPL claimed tax exemption based on the doct...