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M/s Tax Holdings Pvt. Ltd. vs Commissioner of Income Tax | Section 68 of Income Tax Act, 1961 - Addition on Alleged Bogus Share Application Money and Accommodation Entries – Delhi High Court
Facts of the CaseThe assessee, M/s Tax Holdings Pvt. Ltd.,
filed its return for Assessment Year 2002-03 declaring a business loss.
Subsequently, the Assessing Officer received information from the Investigation
Wing t...
Commissioner of Income Tax v. Assessee (Name Not Available) under Section 260A of Income Tax Act, 1961 | Delhi High Court Dismisses Revenue Appeal Due to Low Tax Effect | ITA No. 315/2011 (2011)
Facts
of the Case• The Revenue filed an appeal
before the Delhi High Court challenging the order passed in favour of the
assessee.
• The appeal was registered as ITA No. 315/2011.
• During the hearing, the Cou...
Mod Creations Pvt. Ltd. vs Income Tax Officer (Delhi High Court) – Section 68 of Income Tax Act, 1961 Unexplained Cash Credit Addition Deleted Where Identity, Creditworthiness and Genuineness of Creditors Established
Facts of the Case
The assessee, Mod Creations Pvt. Ltd., was engaged in the
business of trading in imported tailoring accessories.
During Assessment Year 2002-03, the assessee received unsecured
loans agg...
Rolls Royce Plc v. Director of Income Tax (International Taxation) – Permanent Establishment (PE) in India through Indian Subsidiary under Article 5 of India–UK DTAA and Taxability of Profits Attributable to PE
Facts of the CaseRolls Royce Plc was incorporated in England and
Wales and was a tax resident of the United Kingdom. It supplied parts and
equipment to Indian customers, including the Indian Navy, Indian Air Force and
...
Commissioner of Income Tax vs Pfizer Limited – Treatment of Balance Written Back, Business Income and Deduction under Section 80HHC | Delhi High Court
Facts of the Case
The assessee had written back certain expenditure liabilities in
its books of account.
The written-back amount represented balances relating to
expenditure incurred in earlier years.
T...
Commissioner of Income Tax vs Visisth Chay Vyapar Ltd. | Interest on Inter-Corporate Deposit (ICD) Not Taxable as Interest on Loan or Advance under Sections 2(7) & 5 of the Interest-tax Act, 1974 | Delhi High Court
Facts of the CaseVisisth Chay Vyapar Ltd. had placed Inter-Corporate
Deposits (ICDs) amounting to ₹22 crores with Shaw Wallace & Company Ltd.
(SWC). The placement of the ICDs was approved through a Board Resoluti...
Rolls Royce PLC vs Director of Income Tax (International Taxation) | Delhi High Court | Permanent Establishment (PE) in India under India–UK DTAA – Attribution of Profits and Business Connection
Facts of the CaseRolls Royce PLC, incorporated in England and Wales
and a tax resident of the United Kingdom, supplied aircraft engines, parts, and
equipment to Indian customers, including the Indian Navy, Indian Air F...
Rolls Royce PLC vs Director of Income Tax (International Taxation) | Delhi High Court | Permanent Establishment in India under Article 5 of India–UK DTAA and Attribution of Profits to PE
Facts of the
CaseRolls Royce PLC, a company incorporated in England
and Wales and a tax resident of the United Kingdom, supplied aircraft and
equipment to Indian customers including the Indian Navy, Indian Air Force a...
Rolls Royce Singapore Pte. Ltd. vs Assistant Director of Income Tax – Dependent Agent Permanent Establishment (PE), Arm’s Length Principle and Taxability of Business Profits under India–Singapore DTAA | Delhi High Court
Facts of the CaseRolls Royce Singapore Pte. Ltd., a company
incorporated in Singapore, was engaged in supplying spare parts, repair
services, maintenance services, and technical support relating to oil-field
equipment...
Commissioner of Income Tax vs. Vasisth Chay Vyapar Ltd. (2011) – Inter-Corporate Deposits (ICDs) Not Taxable as Interest on Loans or Advances under Sections 2(7) & 5 of the Interest Tax Act, 1974
Facts of the CaseThe assessee company, Vasisth Chay Vyapar Ltd.,
placed Inter-Corporate Deposits (ICDs) amounting to ₹22 crores with Shaw
Wallace & Company Ltd. (SWC) after passing a Board Resolution authorizing
...