PCIT Vs Headstrong Services India Pvt. Ltd

Last updated: 30 December 2020

Court :
Delhi High Court

Brief :
Elementary My Dear Watson‟ is a popular phrase often attributed to Sherlock Homes, the English detective in the works of Sir Arthur Conan Doyle. However, it seems, like the present case highlights, nothing is elementary to the appellant, even when the statute uses clear and explicit language, till the superior courts like the High Court and the Supreme Court repeatedly interpret a section.

Citation :
ITA 77/2019

IN THE HIGH COURT OF DELHI AT NEW DELHI
ITA 77/2019

THE PR. COMMISSIONER OF INCOME TAX -4 ..... Appellant
Through: Mr. Deepak Anand, Advocate. versus

HEADSTRONG SERVICES INDIA PVT. LTD. ..... Respondent
Through:

Reserved on : 03rd December ,2020
Date of Decision: 24th December, 2020

CORAM:
HON'BLE MR. JUSTICE MANMOHAN
HON'BLE MR. JUSTICE SANJEEV NARULA J U D G M E N T

MANMOHAN, J:

1. „Elementary My Dear Watson‟ is a popular phrase often attributed to Sherlock Homes, the English detective in the works of Sir Arthur Conan Doyle. However, it seems, like the present case highlights, nothing is elementary to the appellant, even when the statute uses clear and explicit language, till the superior courts like the High Court and the Supreme Court repeatedly interpret a section.

2. It is pertinent to mention that the present appeal has been filed challenging the order dated 9th November, 2017 passed by the Income Tax Appellate Tribunal (ITAT), whereby the Revenue‟s appeal, being No.6117/Del/2014 for assessment year 2007-08, has been dismissed.

BRIEF FACTS OF THE CASE

3. The respondent-assessee, a wholly owned subsidiary of Headstrong Services LLC, USA, had filed its return of income declaring income of Rs.30,64,480/- for the relevant assessment year. Thereafter, revised return of income was filed on 30thJanuary, 2009 that was processed under Section 143(1) of the Income Tax Act, 1961 (for short „the Act‟) and subsequently, case of the respondent-assessee was selected for scrutiny assessment and notice under Section 143(2) of the Act was issued.

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