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Commissioner of Income Tax, Delhi vs Adidas India Marketing Pvt. Ltd. | Foreign Loan Interest Benchmarking, LIBOR Rate & Allowability of Business Expenditure under Section 37(1) of Income Tax Act, 1961
Facts of the Case
The
assessee was a company associated with Adidas AG, Germany.
The
German company licensed the Adidas trademark to the assessee in India
against royalty payment.
The
assess...
Commissioner of Income Tax vs. [Assessee Name] (ITA No. 713/2009) | Section 68 Share Capital Addition & Onus of Proof
Facts
of the CaseThe Revenue filed an appeal (ITA No.
713/2009) before the High Court of Delhi against the assessee. The primary
dispute arose regarding the addition of share capital under the Income Tax Act.
During ...
CIT vs. Singapore Airlines Ltd.: Whether Supplementary Commission Earned by Travel Agents over Net Fare Attracts TDS under Section 194H of Income Tax Act, 1961
Facts of the Case
The
Revenue preferred a batch of appeals primarily arising from the lead case CIT
vs. Singapore Airlines Ltd. for the Assessment Year 2001-02. The core
issue spanned across multiple ...
Commissioner of Income Tax vs. Singapore Airlines Ltd. (with Connected Matters) | TDS Liability Under Section 194H on Supplementary Commission vs. Concessional Ticket Discounts for Travel Agents
Facts of the Case
The
Revenue preferred a batch of appeals against various foreign and domestic
airlines (including Singapore Airlines, KLM Royal Dutch Airlines, British
Airways, Air France, and Air I...
Commissioner of Income Tax vs. Adidas India Marketing Pvt. Ltd. (Delhi High Court) Interest Payments on Foreign Loans & LIBOR Benchmarking under Section 37(1) of the Income Tax Act, 1961
Facts of the CaseThe Respondent-Assessee is a company incorporated
under the Indian Companies Act and a subsidiary of Adidas India Private
Limited, functioning as a joint venture between Adidas A.G. (Germany) and
Magn...
Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others (2009) | Applicability of TDS Under Section 194H on Supplementary Commission and Concessional Tickets Issued to Travel Agents: Delhi High Court Judgment
Facts of the Case
The
Revenue preferred a batch of appeals against 12 airlines (including
Singapore Airlines, KLM Royal Dutch Airlines, British Airways, Air France,
Air India, and Lufthansa).
The
...
Commissioner of Income Tax vs. M/s. H.B. Stock Holdings Limited – Under Section 260A and Section 36(1)(iii) of the Income Tax Act, 1961
Facts
of the CaseThe Revenue filed an appeal against
the order of the Income Tax Appellate Tribunal (ITAT), which had ruled in favor
of the assessee, M/s. H.B. Stock Holdings Limited. The Assessing Officer (AO)
had m...
Commissioner of Income Tax vs. Magnum International Trading Company (P) Ltd. | Section 80HHC Deduction on Share Sale Profits and Interest Income – Delhi High Court
Facts of the CaseThe assessee, Magnum International Trading Company
(P) Ltd., claimed deduction under Section 80HHC on profits arising from export
activities. While computing such deduction, the assessee included profi...
Commissioner of Income Tax vs. France Air Pvt. Ltd. — Applicability of TDS under Section 194H on Supplementary Commission and Discounted Fares Paid by General Sales Agents (GSA) to IATA Agents
Facts of the Case
The
respondent-assessee acts as a General Sales Agent (GSA) for Air
France Ltd.
During
the Assessment Year 2002-03, the assessee passed on discounted fare
tickets to its Int...
Commissioner of Income Tax vs. Singapore Airlines Ltd. (Along with KLM Royal Dutch Airlines, British Airways, Air India, & Others) | Scope of Section 194H: Applicability of TDS on Supplementary Commission vs. Concessional Tickets
Facts of the Case
Reintroduction
of Section 194H: Section 194H was
reintroduced into the statute book via the Finance Act, 2001, effective
from 01.06.2001. The dispute primarily concerns the period fr...