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Commissioner of Income Tax (International Taxation)–2 vs M/s CSG International Ltd. | Delhi High Court | Section 9 & DTAA | Software Royalty Issue
Facts of the Case
The
assessee, M/s CSG International Ltd., was incorporated in the United
Kingdom and engaged in software-related services.
For
AY 2003–04, it declared income including fees for ...
PR. Commissioner of Income Tax-7 vs Oriental Bank of Commerce Ltd. (Now Merged with Punjab National Bank Ltd.) – Section 14A, 36(1)(vii) & Banking Taxation Issues | Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue
before the Delhi High Court against the order dated 04.03.2022 passed by the
Income Tax Appellate Tribunal concerning Assessment Years 2013-14, 2014-15, a...
Nokia Corporation vs Deputy Commissioner of Income Tax Circle 2(2)(2) International Tax & Ors. | Delhi High Court | Refund Verification & Indemnity Bond Mechanism under Income Tax Law
Facts of the Case
The
petitioner claimed a total refund of ₹29.06 crore for AYs 1997–98
to 2002–03.
The
Revenue verified ₹22.46 crore out of the principal amount.
The
verified amou...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA | Delhi High Court | ITA 489/2023 & 490/2023 | AY 2017-18 & 2019-20 | Profit Attribution to PE, Royalty vs Business Income, FAR Analysis
Facts of the Case
The
appeals were filed by the Revenue against a common order of the ITAT
dated 13.09.2022.
The
matter pertained to Assessment Years 2017-18 and 2019-20.
The
dispute invol...
PR. Commissioner of Income Tax (Central-1) vs VE Commercial Vehicles Ltd – Allowability of Bad Debts & Training Expenses under Sections 36(1)(vii), 36(2) & 37 of Income Tax Act
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT) for
Assessment Year 2011–12.Two primary issues arose:
Deduction claimed by the assesse...
Intertek India Private Limited vs Assistant Commissioner of Income Tax, Circle 10(1), New Delhi | Delhi High Court | Rectification Delay & Interest under Section 244A
Facts of the CaseThe petitioner, Intertek India Private Limited, filed a
rectification application dated 25.05.2016 under Section 154 of the Income Tax
Act, 1961. The grievance raised was that the said rectification ap...
PR. Commissioner of Income Tax (Central)-1 vs VE Commercial Vehicles Ltd. – Allowability of Bad Debts Post Demerger under Sections 36(1)(vii) & 36(2) of the Income Tax Act
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court concerning Assessment Year 2010–11. The dispute
arose from an order passed by the Income Tax Appellate Tribunal (ITAT) dated
...
Samson Healthcare Pvt. Ltd. vs Pr. Commissioner of Income Tax Delhi-7 & Ors. – Delhi High Court Sets Aside Transfer Order Under Section 127 for Non-Consideration of Objections
Facts of the CaseThe petitioner, Samson Healthcare Pvt. Ltd., filed a writ
petition challenging an order dated 25.07.2023 passed under Section 127 of the
Income Tax Act, 1961.By the impugned order, the petitioner’s c...
Filatex India Ltd. vs Deputy Commissioner of Income Tax & Anr. (Delhi High Court, 2023) – Reassessment Notice u/s 148 Held Time-Barred; Interim Stay Granted under Sections 149 & 153A of Income Tax Act
Facts of the
Case
The petitioner is Filatex India Ltd., assessed for AY
2012–13.
A scrutiny assessment under Section 143(3) was completed on 16.03.2015.
A search under Section 132 was conducted on ...
Commissioner of Income Tax (International Taxation)-1 vs Amadeus IT Group SA | Delhi High Court | Section 9, Article 7 & Rule 10 | Profit Attribution to PE
Facts of the CaseThe Revenue filed appeals against a common order passed by
the Income Tax Appellate Tribunal concerning profit attribution to the
Permanent Establishment (PE) of the assessee in India.The dispute revol...