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Galileo International Inc. vs Director of Income Tax | Delhi High Court Clarifies Taxability of Permanent Establishment (PE) Income and Deduction of Expenses
Facts of the
Case
The assessee filed appeals relating to different assessment years.
The primary controversy was whether the assessee had a Permanent
Establishment (PE) in India.
The lower authorities, after...
Ericsson AB vs Additional Director of Income Tax, Range-1, International Taxation, New Delhi [Delhi High Court] – Assessee Must First Exhaust Remedy Before Dispute Resolution Panel (DRP) Under Section 144C of the Income-tax Act, 1961
Facts
of the Case• Ericsson AB challenged a draft
assessment order passed under Section 144C(1) of the Income-tax Act, 1961 for
Assessment Year 2007-08.• The petitioner contended that
the Assessing Officer had fa...
Commissioner of Income Tax vs. Nokia India Pvt. Ltd. [2010] 2010:DHC:2568-DB (Delhi High Court) I Foreign Travel Expenditure of Employees Incurred for Commercial Expediency and Provision for Warranty Held Allowable Deduction – Sections 37(1) & Warranty Provision Principles | Delhi High Court
Facts of the CaseNokia India Pvt. Ltd. claimed deduction of foreign
travel expenses incurred on its employees, particularly field engineers who
were deputed abroad for business assignments.During assessment proceedings...
Commissioner of Income Tax vs. J. K. Industrial Enterprises Pvt. Ltd. – Delhi High Court on Section 37(1), ITA 1327/2010
Facts of the Case:The petitioner, Commissioner of Income Tax,
challenged the income tax assessment order passed in favor of J. K.
Industrial Enterprises Pvt. Ltd., whereby certain expenses claimed by the
assessee were...
Director of Income Tax v. Galileo International Inc. – Delhi High Court Reaffirms Taxability Principles; Revenue Appeals Dismissed Following Binding Precedent
Facts of the
CaseThe Revenue preferred multiple appeals before the
Delhi High Court challenging the order passed in favour of the assessee. The
principal issue involved in the appeals had already been adjudicated by t...
Commissioner of Income Tax vs. Shashi Charla [2010] 2010:DHC:2572-DB (Delhi High Court) I Capital Gains on Sale of Company-Owned Property Cannot Be Assessed in Hands of Directors Under Section 49(1) Based on Family Arrangement – Delhi High Court
Facts of the CaseThe property situated at C-101, Maya Puri
Industrial Area, Delhi, measuring approximately 2829 square yards, was
acquired on 17.01.1966 by Ambitious Gold Nibs Company Private Limited
from the Delhi De...
Cyber Media (India) Ltd. Vs. Commissioner of Income Tax-I & Another | Section 145(1) & Section 209 | (Delhi High Court)
Facts of the CaseThe assessee, Cyber Media (India) Ltd., was engaged
in the business of publishing magazines including Data Quest and PC World. The
company earned income from subscriptions, sale of magazines, advertise...
Director of Income Tax vs. Galileo International Inc. & Connected Appeals – Delhi High Court Reaffirms Earlier Precedent; Revenue Appeals Dismissed
Facts of the
CaseThe Revenue preferred multiple Income Tax Appeals
before the Delhi High Court. The principal issue raised in these appeals had
already been examined and decided by the Delhi High Court in Director of
...
Commissioner of Income Tax vs. SIL Investments Ltd. | Reassessment under Section 147 Cannot Be Reopened Beyond Four Years Solely Due to Retrospective Amendment to Section 80HHC – Delhi High Court
Facts of the
CaseThe assessee, SIL Investments Ltd., had filed its
income tax returns and the assessments were originally completed under the
provisions of the Income-tax Act.Subsequently, Section 80HHC was amended
r...
CIT vs M/s Vardhman Industries Ltd – Income Tax Appeal under Section 194 of the IT Act, 1961
Facts
of the Case
The appeals were
filed by the Income Tax Department (Revenue) against a
group of assessees, including Ravi Dass Garg.
The dispute arose from additions
made by the Assessing O...