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
360
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
188
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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