Team ALA Legal Archive

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
347
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
181
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
89
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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