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Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Section 9, 143(3), 144C, 260A | Permanent Establishment & DTAA Taxability
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, entered into Strategic Oversight Services Agreements
(SOSA) with hotel entities in India for providing advisory and strategi...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of SOSA Services, Royalty vs Business Income & Permanent Establishment under DTAA
Facts of the
case
The assessee, Hyatt International Southwest Asia Ltd., is a
UAE-based company providing strategic and advisory services to hotels
under Strategic Oversight Services Agreements (SOSA).
...
Commissioner of Income Tax (International Taxation)-2 vs. Sh. Hotchand Techchand Punjabi (Delhi High Court) – Section 250(4), Rule 46A, Sections 147, 148, 69B of Income Tax Act – Admission of Additional Evidence & Scope of CIT(A) Powers
Facts of the
CaseThe present matter pertains to Assessment Year
2012–13, wherein the Assessing Officer (AO) initiated reassessment
proceedings under Sections 147 and 148 of the Income Tax Act, 1961 based
on informa...
Commissioner of Income Tax (Exemptions), Delhi vs Indian Evangelical Team – No Substantial Question of Law – Appeal Dismissed (Delhi High Court, AY 2013–14, ITA 699/2023)
Facts of the
CaseThe present appeal was filed by the Commissioner
of Income Tax (Exemptions), Delhi (Appellant/Revenue) against the order
dated 24.03.2021 passed by the Income Tax Appellate Tribunal (ITAT) for the Ass...
Principal Commissioner of Income Tax-7, Delhi vs M/s Timex Group India Ltd. | Delhi High Court | AY 2009-10 | AMP Expenses & International Transactions
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order dated 27.03.2023 passed by the Income Tax Appellate
Tribunal. The dispute pertains to the Assessment Year 2009–10.The Revenue raised...
Principal Commissioner of Income Tax-7, Delhi vs M/s Timex Group India Ltd. (Delhi High Court) – AMP Expenses Not an International Transaction | AY 2009-10
Facts
of the Case
The assessee, M/s
Timex Group India Ltd., incurred AMP expenses during AY 2009-10.
The Revenue
contended that such expenses constituted an international transaction
requiring tra...
PR. Commissioner of Income Tax-1 vs M/s Ansal Properties and Infrastructure Ltd (Delhi High Court) – Deduction under Section 35D on QIB Share Issue | AY 2011-12
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal dated 16.07.2021 for
Assessment Year 2011-12.The Respondent/Assessee, M/s Ansal Properties and
I...
Sanjay Gandhi Memorial Trust & Ors. vs Commissioner of Income Tax (Exemption) & Ors. – Transfer of Assessment to Central Circle under Section 127 of Income Tax Act without CBDT Approval (Delhi High Court, 2023)
Facts of the Case
Multiple
petitioners including charitable trusts, individuals (Sonia Gandhi, Rahul
Gandhi, Priyanka Gandhi Vadra) and a political party (Aam Aadmi Party)
challenged transfer orders. ...
Commissioner of Income Tax (International Taxation)–3 vs Travelport L.P., USA (Delhi High Court, ITA 708/2023 & ITA 709/2023) – Section 153 vs Section 144C | Limitation & PE Attribution
Facts of the CaseThe
present appeals were filed by the Revenue challenging the order dated
09.11.2020 passed by the Income Tax Appellate Tribunal. The Tribunal had
dismissed the Revenue’s appeals primarily on the gr...
Principal Commissioner of Income Tax–7 vs ST Microelectronics Pvt. Ltd. (Delhi High Court) – Software License & Training Expenses Held Revenue in Nature u/s 37 of Income Tax Act
Facts of the
CaseThe appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT) dated 28.09.2020 concerning
Assessment Year 2008–09. The dispute primarily revolved around:
Tr...