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Search Results for "DRP directions"

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High Court

Bombay High Court Directs Demarcation of Dharavi Koliwada Boundaries in Dharavi Redevelopment Project Dispute. The court issued a writ of mandamus to the State of Maharashtra and other respondents to expeditiously determine and finalise the outer boundaries of Dharavi Koliwada, finding inordinate delay in the discharge of official duty.

18 Apr 2026

The petitioner, Dharavi Koli Jamat Trust, filed a writ petition under Article 226 of the Constitution of India seeking a writ of certiorari to call fo...

High Court

Bombay High Court Allows Writ Petition for Non-Compliance of DRP Directions Within Statutory Time Limit Under Section 144C(13) of Income Tax Act, 1961. Failure to Complete Assessment Within One Month of Receiving DRP Directions Renders Transfer Pricing Addition Time-Barred and Non-Est.

10 Oct 2025

The Petitioner, Archroma International (India) Private Limited (formerly Huntsman International (India) Private Limited), filed a Writ Petition under ...

High Court

Bombay High Court Sets Aside Final Assessment Order and Remits Matter to DRP Due to Petitioner's Inadvertent Failure to Inform Assessing Officer of Pending Objections, Subject to Costs of Rs.10,000. Procedural Lapse Condoned Where Objections Were Factually Pending Before DRP, Following Sulzer Pumps Precedent.

3 Mar 2025

The petitioner, Zarah Rafique Malik, an individual investor, challenged the final assessment order dated 28 May 2024 passed under Section 143(3) read ...

High Court

Bombay High Court Quashes Assessment Orders for Violation of Natural Justice in Transfer Pricing Adjustment. Failure to Provide TPO's Draft Order and Opportunity of Hearing Renders Proceedings Void Ab Initio Under Sections 144C and 92CA of Income Tax Act, 1961.

12 Sep 2023

The petitioner, Undercarriage and Tractor Parts Pvt. Ltd., filed its return of income for Assessment Year 2015-2016 on 30 September 2015 declaring a l...

High Court

Bombay High Court Allows Petitions by Offshore Drilling Companies Challenging Reassessment Notices Under Section 148 of Income Tax Act, 1961 — Notices Quashed for Being Time-Barred and Lacking Proper Sanction. Reassessment notices for AY 2014-15 and 2015-16 were issued beyond the four-year time limit under Section 149 without any allegation of failure to disclose material facts, and the sanction under Section 151 was granted without proper application of mind.

4 Aug 2023

The petitioners, Shelf Drilling Ron Tappmeyer Limited, Shelf Drilling J.T. Angel Limited, and Shelf Drilling Trident XII Limited, are companies incorp...

High Court

Bombay High Court Allows Petitions by Offshore Drilling Companies Challenging Reassessment Notices Under Income Tax Act, 1961 — Section 147 Reassessment Invalid Due to Lack of Jurisdictional Condition Precedent. The court held that reassessment notices were issued without proper application of mind and without valid reasons to believe that income had escaped assessment, and quashed the notices.

4 Aug 2023

The petitioners, Shelf Drilling Ron Tappmeyer Limited, Shelf Drilling J.T. Angel Limited, and Shelf Drilling Trident XII Limited, are companies incorp...

High Court

Bombay High Court Allows Revenue's Appeal in Income Tax Case Involving Non-Resident Company - Denial of Treaty Benefits and Business Connection Upheld. The court held that the Tax Residency Certificate is not conclusive and the Assessing Officer can examine the substance of the arrangement to determine treaty eligibility.

16 Jun 2023

The case involves an appeal by the Commissioner of Income Tax (International Taxation) against the order of the Income Tax Appellate Tribunal (ITAT) i...

High Court

Bombay High Court Quashes Assessment Order for Violation of Section 144C(11) Time Limit — DRP Directions Issued Beyond Nine-Month Period Invalid. The court held that the Dispute Resolution Panel's directions under Section 144C(5) of the Income Tax Act, 1961 must be issued within nine months from the end of the month in which the draft assessment order is received, and failure renders the assessment order void.

14 Feb 2022

The petitioner, Shell India Markets Private Limited, a company engaged in retailing petroleum products and supplying lubricants, challenged an assessm...

High Court

Bombay High Court Quashes Assessment Order in Transfer Pricing Case for Violation of Natural Justice — Failure to Provide Show-Cause Notice and Opportunity of Hearing Renders Order Invalid. Petitioner's Objections to Draft Assessment Order Not Considered, Violating Section 144C of Income Tax Act, 1961.

28 Jul 2021

The petitioner, SHL (India) Private Limited, an Indian company and part of the SHL Group, United Kingdom, filed a writ petition under Article 226 of t...

High Court

Bombay High Court Allows Revenue's Appeal in Transfer Pricing Case Due to Non-Application of Mind by ITAT. Tribunal's order set aside for failing to consider the TPO's detailed analysis and rejecting comparables without proper reasoning under Section 92C of the Income Tax Act, 1961.

27 Feb 2020

The appeal was filed by the Pr. Commissioner of Income Tax - 6 under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appe...

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