Delhi High Court Judgments — 2015

The Tribunal held that the assessee had established the source and creditworthiness of the donor, and had discharged the burden of proving the receipt as a gift. The High Court agreed that the AO lacked sufficient material to reject the assessee's claim.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The High Court dismissed these appeals. This decision was made in view of a previous decision by the same court in a similar case.

The High Court dismissed the appeals filed by the revenue. This decision was based on a prior judgment of the same court in a similar case.

The High Court dismissed the appeals filed by the revenue. This decision was based on a prior judgment of the same court in a similar case.

The High Court dismissed the appeals filed by the revenue. This decision was based on a prior judgment of the same court in a similar case.

The High Court dismissed the appeals filed by the revenue. This decision was based on a prior judgment of the same court in a similar case.

The High Court held that the reopening of assessments was invalid as it did not meet the basic legal requirements. Specifically, reopening beyond four years lacked a clear statement of the assessee's failure to disclose material facts, and the AO was silent on a crucial objection.

The High Court dismissed the appeals filed by the revenue. This decision was based on a previous judgment of the same court in a similar case, Pr. Commissioner of Income Tax (Central-II) v. Aakash Arogya Mandir Pvt. Ltd.

The High Court found that the Revenue had filed appeals against the wrong ITAT orders and that the projected questions of law were not relevant to the appeals before it. Consequently, the appeals were dismissed.

The High Court found that the Revenue had filed appeals against the wrong ITAT orders and that the projected questions of law were not relevant to the appeals before it. Consequently, the appeals were dismissed.

The High Court found that the Revenue had filed appeals against the wrong ITAT orders and that the projected questions of law were not relevant to the appeals before it. Consequently, the appeals were dismissed.

The High Court found that the Revenue had filed appeals against the wrong ITAT orders and that the projected questions of law were not relevant to the appeals before it. Consequently, the appeals were dismissed.

The High Court dismissed the appeals filed by the revenue. This decision was based on a previous judgment of the same court in a similar case, Pr. Commissioner of Income Tax (Central-II) v. Aakash Arogya Mandir Pvt. Ltd.

The High Court held that the reopening of assessments was invalid as it was done beyond four years without clearly stating the assessee's failure to disclose material particulars. Additionally, the Assessing Officer failed to address a specific objection raised by the assessee regarding interest on fixed deposits.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The tribunal correctly applied the multiplier of 7 for loss of future income, considering the claimant's functional disability and potential future employment. Medical expenses were also rightly awarded as they were not reimbursed by the employer.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The High Court found that the Revenue had filed appeals against the wrong ITAT orders and that the projected questions of law were not relevant to the appeals before it. Consequently, the appeals were dismissed.

The High Court noted that the appeals were incorrectly filed and the projected questions of law did not arise for consideration. Consequently, the appeals were dismissed.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The High Court noted that the appeals were filed incorrectly, addressing the wrong set of ITAT orders. The projected questions of law were also found to be irrelevant to the appeals as presented.

The High Court held that the reopening of assessments was invalid. It found that the reasons for reopening did not meet the legal requirements, particularly for assessments beyond four years, and that the Assessing Officer failed to address specific objections raised by the assessees.

The High Court dismissed the appeals filed by the revenue. This decision was based on a prior judgment of the same court in a similar case.

The High Court held that the reopening of assessments was invalid as it did not meet the basic legal requirements. Specifically, reopening beyond four years lacked a clear statement of the assessee's failure to disclose material facts, and the AO was silent on a crucial objection.

The High Court held that notional interest, not accrued or received, cannot be considered as income derived from an eligible undertaking for Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was upheld.

The Delhi High Court held that reopening the assessment after four years solely based on a previously existing Supreme Court judgment not noticed by the AO amounts to a 'change of opinion' and is impermissible. The threshold requirement of tangible material indicating escapement of income due to failure to disclose was not met.

The High Court held that notional interest, not actually accrued or received, cannot be considered as income derived from an eligible undertaking for the purpose of Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was found to be valid.

The High Court held that notional interest, not accrued or received, cannot be considered as income derived from an eligible undertaking for Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was upheld.

The High Court held that notional interest, not accrued or received, cannot be considered as income derived from an eligible undertaking for Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was upheld.

The High Court held that notional interest, not actually accrued or received, cannot be considered as income derived from an eligible undertaking for the purpose of Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was found to be valid.

The High Court held that notional interest, not actually accrued or received, cannot be considered as income derived from an eligible undertaking for the purpose of Section 10A deduction. The CIT's exercise of jurisdiction under Section 263 was found to be valid.

The High Court of Delhi dismissed the present appeal (ITA 796/2015) filed by the Pr. Commissioner of Income Tax-8 against Sardar Exhibitors Pvt. Ltd. The dismissal was predicated on the Court's prior decision dated 31st July, 2015, in ITA No. 534/2015, which involved the same appellant and respondent. The reasoning for the dismissal is that the present appeal is governed by the precedent set in the earlier case. The operative direction is the dismissal of the appeal. No issues were expressly left undecided, as the appeal was disposed of on the basis of the prior ruling.

The Delhi High Court held that reopening the assessment after four years solely based on a previously existing Supreme Court judgment not noticed by the AO amounts to a 'change of opinion' and is impermissible. The threshold requirement of tangible material indicating escapement of income due to failure to disclose was not met.

The ITAT correctly held that the AO had not applied his mind to the material and failed to form an independent belief that income had escaped assessment, which is a jurisdictional requirement for reopening under Section 147/148.

The ITAT correctly held that the AO had not applied his mind to the material and failed to form an independent belief that income had escaped assessment, which is a jurisdictional requirement for reopening under Section 147/148.

The High Court held that the surplus reflected in the assessee's books could not be taxed as undisclosed income under Chapter XIV-B. It also ruled that the denial of approval under Section 10(23C)(vi) solely for belated submission of the audit report was unsustainable.

The High Court held that the assessees did not adopt a uniform scientific method to estimate transit breakages. Therefore, the provision was considered a contingent liability and not allowable as a business expenditure.

The High Court held that the assessees did not adopt a uniform scientific method to estimate transit breakages. Therefore, the provision was considered a contingent liability and not allowable as a business expenditure.

The Tribunal allowed the assessee's plea, holding that a correction in the computation of income due to an incorrect currency conversion did not constitute a new claim and was permissible before appellate authorities. It also held that claiming Section 80HHE in one year did not preclude claiming Section 10A in a subsequent year for the same unit.

The Tribunal allowed the assessee's plea, holding that a correction in the computation of income due to an incorrect currency conversion did not constitute a new claim and was permissible before appellate authorities. It also held that claiming Section 80HHE in one year did not preclude claiming Section 10A in a subsequent year for the same unit.

The High Court held that the assessees did not adopt a uniform scientific method to estimate transit breakages. Therefore, the provision was considered a contingent liability and not allowable as a business expenditure.

The High Court held that the assessees had not adopted a uniform scientific method to estimate transit breakages. Therefore, the provision was considered a contingent liability and not allowable as a deduction.

The High Court held that the assessees did not adopt a uniform scientific method to estimate transit breakages. Therefore, the provision was considered a contingent liability and not allowable as a business expenditure.

The ITAT held that scrap sales and exchange rate differences should be included in export turnover, and interest on FDRs, if linked to business activities, should be considered part of business profits for Section 10B calculation. The High Court agreed with the ITAT.

The High Court found that the ITAT's decisions on deductions and disallowances were based on facts or covered by previous judgments. Therefore, no substantial question of law arose for consideration.

The Tribunal held that there was a cleavage of opinion on the mandatory nature of Section 80AC, and thus the CIT's jurisdiction under Section 263 was not justified. The High Court agreed that no substantial question of law arose.

The Delhi High Court held that the issue of deductions under Sections 80HH, 80I, and 80IA was covered by a previous decision in favor of the assessee. The court also found no substantial question of law regarding the disallowance of losses from Unit-I and Unit-II, deeming the ITAT's findings plausible based on facts.