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Commissioner of Income Tax vs. Maruti Udyog Limited | Section 260A Appeal on Taxability of Supervision Fees as FTS under the Indo-Japan DTAA
Facts of the Case
The
Assessee's Business & Appeal: The
Assessee filed appeals before the Income Tax Appellate Tribunal (ITAT)
concerning the taxability of certain receipts.
Admission
of ...
Commissioner of Income Tax vs Mohan Meakin Ltd. & Connected Appeals – Deletion of Addition on Notional State Excise Duty in Closing Stock and Taxability of Gain on Sale of Low-Value Assets under Section 45 of Income Tax Act, 1961 | Delhi High Court
Facts of the
CaseThe Assessing Officer enhanced the value of the
assessee’s closing stock by adding State Excise Duty on a notional basis,
proceeding on the assumption that excise duty became payable at the stage of...
Commissioner of Income Tax vs. Maruti Udyog Limited / Japanese Equipment Supplier (ITA No. 404/2008) — Taxability of Supervision Fees as Fees for Technical Services (FTS) under Articles 7 & 12 of Indo-Japan DTAA vs. Equipment Supply Simpliciter
Facts of the Case
The
present appeals arise out of the order of the learned Income Tax Appellate
Tribunal (ITAT) dated October 15, 2003.
During
the original proceedings before the ITAT, the Appella...
Commissioner of Income Tax vs. Maruti Udyog Limited (Assessee) | Taxability of Supervision Fees as Fees for Technical Services (FTS) under Article 12 vs. Article 7 of Indo-Japan DTAA: ITAT Remand for De Novo Inquiry under Section 260A
Facts of the CaseThe case involves a batch of cross-appeals (ITA
Nos. 404/08, 409/08, etc.) filed before the High Court of Delhi involving the
Assessee and the Revenue. During the prior proceedings before the Income Ta...
CIT vs. Maruti Udyog Limited (And Connected Appeals) | Taxability of Supervision Fees under Indo-Japan DTAA: Fees for Technical Services (FTS) vs. Supply of Equipment Simpliciter under Section 9(1)(vii) of Income Tax Act and Articles 7 & 12 of Indo-Japan DTAA
Facts of the Case
The
Assessee entered into transactions involving the supply of industrial
equipment along with associated supervision services to Maruti Udyog
Limited.
A
dispute arose regard...
Commissioner of Income Tax v. Pawan Gupta (Following Precedent) – Revenue Appeal Dismissed by Delhi High Court under Income Tax Act, 1961 | ITA No. 1032/2009
Facts of the
Case
The Revenue preferred an appeal before the Delhi High Court under
the provisions of the Income-tax Act, 1961.
The appeal sought adjudication on an issue which had already been
considere...
Section 201 & Section 201(1A) of the Income Tax Act, 1961 – Liability to Pay TDS and Limit of Interest Liability When Deductee is a Government Undertaking
Facts
of the CaseThe assessee, M/s Trans Bharat
Aviation (P) Ltd., is engaged in the business of operating air taxis. During
verification proceedings, the Assessing Officer (AO) discovered that the
assessee had made ...
Commissioner of Income Tax vs. Suzuki Motor Corporation | Taxation of Supervision Fees as Fees for Technical Services (FTS) under Indo-Japan DTAA: Scope of Articles 7 & 12 Explained | Delhi High Court (ITA No. 276/2008)
Facts of the CaseThe case involves cross-appeals (including ITA No.
276/2008) filed by both the Assessee (Suzuki Motor Corporation / associated
entities) and the Revenue (Income Tax Department). The Assessee had earned...
Commissioner of Income Tax vs. Maruti Udyog Limited (In re: Assessee/Japanese Equipment Supplier) | Scope of Fees for Technical Services (FTS) under Articles 7 & 12 of Indo-Japan DTAA vs. Equipment Supply Simpliciter: Delhi High Court Remands Matter to ITAT for De Novo Adjudication on Admitted Additional Ground
Facts of the CaseThe case involves cross-appeals (ITA No. 404/2008
and others) filed by both the Assessee and the Revenue before the Hon’ble High
Court of Delhi. The dispute arose out of an order passed by the Income...
Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others: Applicability of TDS under Section 194H on Supplementary Commission of Airline Travel Agents
Facts of the Case
The
Revenue preferred a batch of appeals against various international and
domestic airlines (including Singapore Airlines, KLM Royal Dutch Airlines,
British Airways, Air France, Air...