Satisfaction Note without Date Supplied to Petitioner after 2 years : Gujarat HC Quashes Notice u/s 153C of Income Tax Act

Direct Tax/ Income Tax, Income Tax Act 1961 0
2
GUJARAT HIGH COURT: Virat Alloys Private Limited v. The Assistant Commissioner of Income Tax Circle, Gandhinagar (SCA No. 5039/2024) Background: The petitioner company filed its revised return of income for the A.Y 2015-16 on 09.03.2017 declaring its income of Rs. Nil. A search was carried out in case of M/s World Window Group. It was …
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Delhi High Court upholds non-taxability of fees paid to international law firm, overrules Virtual PE theory

Direct Tax/ Income Tax, Income Tax Act 1961 0
1
DELHI HIGH COURT: Commissioner of Income Tax, International Taxation-1, New Delhi v. Clifford Chance Pte Ltd (ITA 353/2025) Background: The assessee, a Singapore-based non-resident law firm, filed NIL income returns for AYs 2020-21 and 2021-22. The AO alleged that the assessee had a service Permanent Establishment (“PE”) and a virtual service PE in India under …
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Maintainability of proceedings under Section 153C against a person whose premises were searched.

Direct Tax/ Income Tax, Income Tax Act 1961 0
0
KARNATAKA HIGH COURT: Sri. Kewal Chand Jain v. Assistant Commissioner of Income Tax (W.P. No. 30135/2021) Background: The petitioner challenged assessment order u/s 153C r/w Section 144 of the Income-tax Act, 1961. His residential premises were subjected to a search u/s 132, pursuant to which certain documents were seized. Despite search being conducted at his …
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Interest is payable on tax collected without authority of law — retention amounts to unjust enrichment

GST / Goods & Service Tax 0
104
Bombay HC: West India Continental v. UOI and Ors. Background: The petitioner, West India Continental Oils Fats Pvt. Ltd., engaged in importing palm oil, had paid ₹2.62 crore as IGST on ocean freight under reverse charge, in terms of Notifications No. 8/2017 and 10/2017 – Integrated Tax (Rate). Subsequently, these notifications were declared unconstitutional …
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Kerala High Court Quashes Appellate Order, Mandates Liberal Approach to Evidence in GST Appeal

GST / Goods & Service Tax 0
74
Kerala High Court- U.S. Technology International Pvt. Ltd. vs. The State of Kerala & Ors. :WP(C) No. 14760 of 2025   Background: The petitioner challenged an adverse assessment order for FY 2018-19 where tax was demanded due to a mismatch between GSTR-3B and GSTR-2A figures. The petitioner claimed this discrepancy stemmed from a data duplication …
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Maintainability of writ petition rejected in view of functional GSTAT and availability of appellate remedy subject to statutory pre-deposit

GST / Goods & Service Tax 0
171
Orissa High Court.- Abhijit Nayak vs The Commr. of (CT & GST) and Ors. : Writ Petition No. 32643 of 2025 Background:- The petitioner assailed the order dated 8th February, 2022 passed under Section 74 of the GST Act for the tax periods July, 2017 to March, 2018, which stood affirmed by the Appellate Authority …
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Restriction on Reopening Tax Demand Upon Acceptance of Explanation Under Section 61 of Delhi GST Act: Quashing of Subsequent Demand Notice Under Section 73

GST / Goods & Service Tax 0
96
Delhi High Court: Kemexel Ecommerce Pvt. Ltd. v. STO: Writ Petition No. 16555/2025 Background: Kemexel Ecommerce Pvt. Ltd. received a notice under Section 61 of the Delhi GST Act regarding discrepancies in its GST returns for 2019-2020. After submitting explanations and documents, the tax department accepted the petitioner’s explanation and closed the matter by order …
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Supreme Court Clarifies Restriction Under S. 80-IA(9) On Claiming Cumulative Deductions Under S.80IA & 80-HHC.

Direct Tax/ Income Tax 0
572
Supreme Court: Shital Fibers Ltd. v. Commissioner of Income Tax (and connected cases) Background: In this case, the appellant had claimed deductions under Section 80-HHC (export profits) and Section 80-IA/80-IB (industrial profits). However, the Income Tax Department disallowed these claims, contending that Section 80-IA (9) prohibits availing double benefits on the same profits, a …
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Bombay HC: RBI subsidy under the Export Credit Scheme is not taxable as “interest” under Section 2(7) of the Interest Tax Act, as it does not stem from any loan or advance

Direct Tax/ Income Tax 0
355
Bank of India v. DCIT Background: The assessee, a public sector bank, received ₹12.93 crore from the RBI under the Export Credit (Interest Subsidy) Scheme, 1968, as compensation for offering export credit to borrowers at concessional interest rates. While filing its return for AY 1992–93, the assessee excluded this subsidy from chargeable interest under …
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Telangana HC: Payments made in the ordinary course of business to a parent company were held not to be deemed dividends under Section 2(22)(e)

Direct Tax/ Income Tax 0
8,372
M/s. Prasad Film Laboratories Pvt. Ltd. v. ACIT Background: The appellant made regular payments to its parent company during the course of business, which were treated by the Assessing Officer as deemed dividends under Section 2(22)(e) of the Income Tax Act. The ITAT remanded the matter back to assessees whether accumulated profits existed on …
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