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Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009): Delhi High Court Verdict on Section 195 TDS Liability and Treatment of Software Reservation Payments to Foreign Entities as Business Income vs. Royalty under DTAA
Facts of the Case
The
respondent/assessee, Sahara Airlines Ltd., entered into operational
arrangements with two foreign entities: M/s. Amadeus Marketing (a
Spanish company) and M/s. Galileo Internatio...
Commissioner of Income Tax, Delhi-IV v. M/s Insilco Ltd. | CIT v. M/s Saw Pipes Ltd. – Bona Fide Belief Does Not Exempt Assessee from Interest Liability under Section 234B of the Income Tax Act
Facts of the Case
M/s
Insilco Ltd. filed its return declaring nil income for Assessment Year
1990-91.
The
assessee adjusted interest income earned on deposits against interest paid
on deferred...
Commissioner of Income Tax, Delhi-I vs. Advance Detergents Ltd. | Interest on Delayed Payment from Customers Eligible for Deduction under Section 80-IA of the Income Tax Act – Delhi High Court
Facts of the CaseAdvance Detergents Ltd., an industrial undertaking engaged in
manufacturing activities, filed its return of income and claimed deduction
under Section 80-IA of the Income Tax Act.During the assessment ...
Commissioner of Income Tax vs. Sahara Airlines Ltd. | Tax Deduction at Source Under Section 195 on GDS Software Reservation Payments to Foreign Companies: Royalty vs. Business Income Controversy Under DTAA
Facts of the Case
The
respondent/assessee, Sahara Airlines Ltd., entered into operational
agreements with two foreign companies: M/s. Amadeus Marketing (a Spanish
entity) and M/s. Galileo Internationa...
Director of Income Tax vs Indian National Science Academy (INSA) | Exemption under Section 10(21) of Income Tax Act and Approval under Section 35(1)(ii) – Delhi High Court
Facts of the Case
The
Indian National Science Academy (INSA) was established to promote
scientific research, scientific knowledge, and national welfare through
scientific advancement.
For
more...
Commissioner of Income Tax, Delhi-II vs. Maharashtra Seamless Ltd. | Section 80HHC Deduction on DEPB Receipts, Delayed Payment Interest, Rental Income & Explanation (baa) – Delhi High Court
Facts of the CaseMaharashtra Seamless Ltd. claimed deductions under Sections
80HHC, 80-IA and 80-IB in respect of several categories of receipts arising
during the course of its manufacturing and export business.The di...
[Petitioner] v. Transfer Pricing Officer & Anr. — Sections 92CA(3) & 144C, Income-tax Act, 1961 — Objections to ALP Methodology Must First Be Raised Before the DRP
Facts of the Case
The
Petitioner filed a Writ Petition under Article 226 of the Constitution of
India to challenge an order dated October 23, 2009, issued by the Transfer
Pricing Officer (TPO) under S...
Commissioner of Income Tax, Delhi-II vs. Maharashtra Seamless Ltd. | Sections 80HHC, 80-IA & 80-IB – DEPB Benefits, Delayed Payment Interest, Business Income and Section 263 Revision – Delhi High Court
Facts of the CaseMaharashtra Seamless Ltd. claimed deductions under Sections
80HHC, 80-IA and 80-IB in respect of various categories of income.The disputes before the Court arose from several assessment
years and invol...
Commissioner of Income Tax vs Aero Traders (P) Ltd. | Penalty under Section 271(1)(c) Cannot Be Levied on Estimated Additions – Delhi High Court
Facts of the CaseThe assessee company was engaged in the business of
manufacturing and exporting shoe uppers, primarily to the erstwhile USSR.
Following the disintegration of the USSR, the assessee suffered substantial...
D.T. & T.D.C. Ltd. v. Assistant Commissioner of Income Tax [Delhi High Court] – Reassessment under Sections 147/148 Invalid on Mere Change of Opinion
Facts of the CaseThe Government of National Capital Territory of Delhi
authorized Delhi Tourism & Transportation Development Corporation Limited
(DTTDC) to operate liquor vends throughout Delhi.Under Government dir...