In the complex world of Indian income tax law, few provisions spark as much debate as . This section empowers tax authorities to initiate against persons other than the one searched, based on documents seized during a . A pivotal judgment on this front came from the in (often referenced in cases like [
#Section153C, #IncomeTaxIndia, #PepsicoJudgment
PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR … Respondents ... Commissioner of Income Tax: (2013) 214 T....
PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR … Respondents ... Commissioner of Income Tax: (2013) 214 T....
PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR PEPSICO INDIA HOLDINGS PRIVATE LIMITED… Petitioner Versus ASSISTANT COMMISSIONER OF INCOME TAX & ANR … Respondents ... Commissioner of Income Tax: (2013) 214 T....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
Ltd. Vs. Assistant Commissioner of Income Tax, WP (C) No.415/2014 and other connected matters, this court had occasion to examine the very provisions which are under consideration in the matters before us. In the judgement delivered on 07.08.2014 in the case of Pepsi Foods Pvt. Ltd. ... Commissioner of Income Tax: (2013) 214 Taxman 558; Commissioner of Income Tax#HL_END....
It was explained in Pepsico India Holdings (P) Ltd v. Assistant Commissioner of Income Tax (supra) and reiterated in Pepsi Foods (P) Ltd. v. ... The two decisions that are relevant in this context are Pepsico India Holdings (P) Ltd v. Assistant Commissioner of Income Tax (s....
“From the foregoing discussion, it is evident that in order that the Assessing Officer of the searched person comes to the satisfaction that documents or materials found during the search belong to a person other than the searched person, it is necessary that he arrives at the satisfaction that the said documents or materials do not belong to the searched person.” Subsequently, the legal position was reiterated in Pepsico India Holdings P. Ltd. v. Assistant Commissioner of Income Tax (2015) 370 ITR 295 (Del), where after discussing the decision in Savesh Kumar Agarwal v. Union of I....
Vs. Grocery Market & Shops Board, reported in (2016) 4 SCC 493, on the point of contractual labourers who were employed through Contractors, are entitled for terminal benefits as such as provident fund and gratuity has observed that: The Hon’ble Apex Court in case of Pepsico India Holding (P) Ltd.
370 ITR 295 (Del), Commissioner of Income-tax-7 v. RRJ Securities Ltd. [2016] 380 ITR 612 (Del), Commissioner of Income-tax (Central) v. Gopi Apartment [2014] 365 ITR 411 (All) and Commissioner of Income-tax v. Mechmen 11-C [2016] 380 ITR 591 (MP). 16. Mr Sabharwal referred to the decisions of this Court in Pepsico India Holdings (P.) Ltd. v. Assistant Commissioner of Income-tax [2015]
In the background of these facts and circumstances we are of the opinion that the case is squarely covered by the ratio laid down by the above mentioned two decisions viz. Gujarat Power Corporation Ltd. v. Assistant Commissioner of Income Tax (supra) and Commissioner of Income Tax v. Kelvinator of India Ltd. (supra). Counsel for the petitioner has further taken up yet another decision in case of Swati Saurin Shah v. Income Tax Officer, Ward 5(2)(4) reported in [2016]
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