namely Shri Anup Kumar Lakhotia,
director of Bhawani Alumina Products Pvt. Ltd., Samsung Estate Pvt. Ltd. and Lakhotia
Diagnostic Services Pvt. Ltd. Shri ... Director of M/s Samsung Estates Pvt. Ltd.
appeared and furnished the documents such as copy of Aadhar, PAN, copy of balance
sheet and profit
seller of
the share (assessee) and the purchaser of the share (Samsung Estate Pvt. Ltd.).
5. Contrary to that the Ld. A.R supports ... Director of the share
applicant of the assessee company i.e. Samsung Estate Pvt. Ltd Company. A statement
on oath of Sri Anup Kr. Lakhotia
upholding Assessing Officer's action adding
difference in incentives received from Samsung India Electronics Pvt. Ltd. of
₹18,43,189/- as well as making ... making addition of ₹18,43,189/- on account of incentive received from
Samsung India Electronics Pvt. Ltd. We notice that
judgment of the Karnataka High Court in the case of CIT v. Samsung
Electronics Co. Ltd. [2009] 185 Taxman 313 /[2010] 320 ITR 209 , relied ... binding precedent, the judgment of
Karnataka High Court in the case of Samsung Electronics Co. Ltd. (supra) would not
apply to the cases where
decision in
the case of CIT 'Vs. Samsung Electronics Co. Ltd (Karnataka High Court
4
ITA No.895/Kol/2017
M/s. Goodricke Group ... Thus the ruling of the Hon'ble Karnataka High
Court in Samsung Corporation's case that the moment there is a remittance
decision in the case of CIT 'Vs.
Samsung Electronics Co. Ltd (Karnataka High Court 320 ITR 209) was due to
erroneous appreciation ... Thus
the ruling of the Hon'ble Karnataka High Court in Samsung Corporation's case that
the moment there is a remittance
that this view has also been taken in case of M/s Samsung Electronics by
Hon'ble Karnataka High Court. In view of this ... Corporation's case and Hon'ble Karnataka
High Court in Samsung Electronics case relied upon by the ld AO have no application
Delhi High Court in the case of CIT v. Samsung India Electronics Ltd.
2013 37 taxmann.com 239 (Del. HC.), approved the following finds
Delhi High Courts in the case of CIT Vs. Samsung India
Electronics Ltd [ 2013] 37 taxmann.com 239 (Delhi)/(2013) 356 ITR 354
(Delhi ... Delhi)
HIGH' COURT OF DELHI
Commissioner or Incometax
v.
Samsung India Electronics Ltd.~
SANJlV KHANNA AND SANJEEV SACHDEVA, JJ.
IT APPEAL
honourable Karnataka High Court in
the case of CIT vs. Samsung Electronics Company Ltd. (Supra )
14.3. The Hon'ble Delhi High Court ... High Court in the case ofCOMMISSIONER OF INCOME TAX
& ANR. VS. SAMSUNG ELECTRONICS CO. LTD. & ORS. (Supra ), held as follows [Head
Notes
