Search Results for "assessment error"

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Search Results for "assessment error"

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High Court

High Court of Bombay Dismisses Revenue's Appeal Against 3% Disallowance on Bogus Purchases; Upholds ITAT's Profit Estimation Approach. The Court held that since the Tribunal's findings that the purchases were bogus had attained finality and sales were not disputed, restricting the addition to 3% of peak purchases was justified without invoking Section 69C of the Income Tax Act, 1961.

7 Apr 2025

The appeals arose from income tax assessment proceedings for Assessment Years 2009-10 and 2010-11, concerning the respondent-assessee, a trader in ele...

Supreme Court

Supreme Court Dismisses Revenue's Appeal in Income Tax Act Case Upholding Revisional Jurisdiction. Commissioner Validly Set Aside Assessment Order as Payment to Shareholders Was Not 'Cost of Improvement' Under Capital Gains Computation Under Sections 48 and 263 of Income Tax Act, 1961.

6 Apr 2023

The dispute arose from an income tax assessment concerning the sale of a property named 'Paville House' by the respondent assessee, a company engaged ...

High Court

Bombay High Court Dismisses Revenue's Appeal in Transfer Pricing and Inventory Valuation Case. Management fees paid to associated enterprise held allowable as services rendered and benefit derived; provision for obsolete inventory allowed following Rotork Controls.

8 Sep 2022

The appeal was filed by the Pr. Commissioner of Income Tax, Pune under Section 260A of the Income Tax Act, 1961 against the order dated 14th June, 201...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 for Lack of Fresh Material — Audit Objection Cannot Form Reason to Believe Income Escaped Assessment. The court held that a notice to reopen assessment based solely on an audit objection, without independent application of mind by the Assessing Officer, is invalid as it amounts to a change of opinion.

1 Feb 2013

The petitioner, NTUC Income Insurance Co-operative Ltd., a company incorporated in Singapore and registered with SEBI as a Foreign Institutional Inves...

High Court

Bombay High Court Dismisses Assessee's Appeal in Income Tax Revision Case for Lack of Inquiry by Assessing Officer. Revision under Section 263 of Income Tax Act, 1961, sustained as Assessing Officer failed to examine revenue reconciliation and reimbursement of expenses, making assessment order erroneous and prejudicial to Revenue.

19 Jun 2026

The appellant-assessee, Mirum Digital Pvt. Ltd., is engaged in digital marketing and buys media space from online platforms like LinkedIn, Google, etc...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction — Dell India Pvt. Ltd. v. Joint Commissioner of Income Tax. Notice under Section 148 of Income Tax Act, 1961 issued without proper sanction and by officer lacking territorial jurisdiction over assessee.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is a company engaged in the manufacture and sale of computer hardware and related products. For the Assessment Y...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material. Reopening Under Section 148 of Income Tax Act, 1961 Based on Mere Change of Opinion on Provision for Unascertained Liabilities is Invalid.

26 Feb 2024

The petitioner, Bajaj Auto Limited, filed its return of income for Assessment Year 2016-17 on 29 November 2016, declaring total income of Rs. 4,860,25...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Revision Case — Commissioner's Revision Under Section 263 Held Invalid as Assessment Order Was Not Erroneous or Prejudicial to Revenue. The Court upheld the ITAT's finding that the twin conditions for invoking Section 263 of the Income Tax Act, 1961 were not satisfied.

24 Jul 2017

The Principal Commissioner of Income Tax, Goa, appealed against the order of the Income Tax Appellate Tribunal (ITAT), Panaji, dated 28/11/2014, which...

High Court

Madras High Court Allows Appeal in Income Tax Bad Debt Write-Off Case — Assessee Entitled to Deduction for Debts Written Off in Books Even if Not Recognized by Debtor. The court held that under Section 36(1)(vii) read with Section 36(2) of the Income Tax Act, 1961, the only condition for deduction of bad debts is that the debt must be written off as irrecoverable in the books of the assessee, and there is no requirement of acknowledgment by the debtor.

27 Jan 2025

The appellant, M/s. Citadel Fine Pharmaceuticals Ltd., filed a return of income for assessment year 2009-10 under the Income Tax Act, 1961. The Assess...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Case Regarding Deductions Under Sections 36(1)(vii) and 36(1)(iii) of the Income Tax Act, 1961. Tribunal's order setting aside Commissioner's revision under Section 263 upheld as Assessing Officer had made proper inquiries and formed an opinion.

5 Aug 2022

The appeal was filed by the Pr. Commissioner of Income Tax-14, Mumbai (appellant-revenue) under Section 260-A of the Income Tax Act, 1961, against the...

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