Legal fiction created u/s. 2 (22)(e) enlarges definition of dividend only and legal fiction is not to be extended further for broadening concept of share holders.
In a significant decision, ITAT Delhi quashes assessment order in Rajender Agarwal Vs ACIT case, citing abatement under Section 153A after a search. Detailed analysis of the legal arguments and implications.
Read the full text of ITAT Delhi’s order in Orient Clothing Co. vs. ACIT. Penalty under section 271(1)(c) deleted due to vague notices. Analysis and implications discussed.
Read the full text of ITAT Delhi’s order dismissing SSC Hospitality Pvt Ltd’s appeal due to non-compliance with statutory notices and failure to produce evidence under Section 143(3) of the Income Tax Act.
ITAT Delhi cancels penalty imposed under section 271E of the Income Tax Act on Pawan Kumar for loan repayment via bank transfer, challenging jurisdiction and citing legal grounds. Full text of the order included.
Sunil Dandriyal vs JCIT case underscores significance of understanding the correct starting point for calculating the time limit for penalty proceedings under Section 271D of the Income Tax Act. The decision reinforces the principle that the initiation of penalty proceedings by the AO, rather than the issuance of a show-cause notice by the JCIT, triggers the commencement of the statutory time limit.
Explore the ITAT Delhi ruling on Section 68, as it clarifies the applicability to unexplained cash credits and purchase costs in Ishwar R Pujara Vs ACIT case.
Explore Ambience Developers vs. JCIT case: ITAT Delhi holds no penalty for technical breach under section 272A(2)(k) of the Income Tax Act. Detailed analysis and key insights.
ITAT Delhi acknowledged the significance of jurisdictional facts and held that a quasi-judicial authority must decide the issue of jurisdiction when raised. The lack of a clear decision on jurisdiction prompted the ITAT to set aside the PCIT’s order and remand the matter for a fresh decision, including the preliminary issue of jurisdiction.
ITAT Delhi cancels penalty under section 271(1)(c) in Identity Wellness Centre case. Displacement of fair market value supported by valuation report by AO.
