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Commissioner of Income Tax vs. M/s Expeditors International (India) Pvt. Ltd.: Applicability of Section 40(a)(i) and TDS under Section 195 on Reimbursement of Global Management and Communication Uplink Expenses
FACTS OF THE CASE
The
respondent-assessee is an Indian private limited company engaged in supply
chain management, logistics, and freight forwarding across road, rail,
air, or ship routes within and o...
Commissioner of Income Tax Vs. Lovlesh Jain (With CIT Vs. Shashi Kant Mittal) | Scope of 'Manufacture' and 'Export' for Gold Jewellery Job Work under Sections 10A & 10B of the Income Tax Act, 1961
FACTS OF THE CASE
ITA
No. 1223/2011 (Lovlesh Jain): The assessee received
standard gold (24-carat bars, bricks, or biscuits) supplied free of cost
by Ramdan Jewellery, Dubai. The assessee converted th...
Director of Income Tax vs. Asia Satellite Telecommunication Co. Ltd. – Taxability of Satellite Service Receipts under Section 9(1) of the Income Tax Act, 1961
Facts of the CaseThe Revenue (Appellant) filed appeals against a common
judgment and order passed by the Income Tax Appellate Tribunal (ITAT) on May
24, 2011 (in ITA Nos. 5004-5005/Del/2010). The ITAT had ruled in favo...
Commissioner of Income Tax vs. Shashi Kant Mittal (and Lovlesh Jain) | Section 10A & 10B Income Tax Act | Conversion of Gold Bars into Jewellery as Manufacture for Export Deductions
Facts of
the Case
Assessee
Units & Operations: The cases involve assessees
operating units dedicated to processing gold. In ITA Nos. 67/2010 and
458/2010, the assessee (Shashi Kant Mittal) ...
Commissioner of Income Tax (TDS) vs. M/s American Express Bank Ltd. – Bona Fide Short Deduction of TDS Does Not Avoid Assessee-in-Default Status; Interest Under Section 201(1A) Mandatory | Delhi High Court
Facts of the CaseThe Revenue filed appeals against orders of the Income Tax
Appellate Tribunal relating to the financial year 1992-93 involving American
Express Bank Ltd.The dispute arose because the assessee had not d...
Commissioner of Income Tax (TDS) vs. M/s American Express Bank Ltd.: Whether Employer’s Bona Fide Belief Negates 'Assessee in Default' Status and Mandatory Interest Under Section 201 and Section 201(1A) of the Income Tax Act, 1961
Facts of the Case
The
Revenue preferred three cross-appeals (ITA Nos. 74/2003, 75/2003, and
653/2005) pertaining to the financial year 1992-93 against the orders of
the Income Tax Appellate Tribunal (...
Commissioner of Income Tax (TDS) vs. M/S American Express Bank Ltd (2011) | Scope of 'Assessee in Default' and Mandatory Interest under Section 201/201(1A)
Facts of the Case
Appeals
and Financial Year: The Revenue filed three interconnected
appeals (ITA Nos. 74/2003, 75/2003, and 653/2005) against the orders of
the Income Tax Appellate Tribunal (ITAT). A...
Director of Income Tax vs. Ericsson Radio System A.B. (2011) – Taxability of Cross-Border Turnkey Telecommunication Equipment and Software Supplies Under Section 9(1) of Income Tax Act and India-Sweden DTAA
Facts of the Case
The
Assessee: M/s. Ericsson Radio Systems A.B. (ERA) is a
resident corporate entity incorporated under the laws of Sweden and a 100%
subsidiary of Telefonakitiebolaget L.M. Ericsson ...
Director of Income Tax vs. Ericsson Radio System A.B. (2011:DHC:12090-DB) | Taxability of Offshore Supply of Telecommunication Hardware and Embedded Software under Section 9(1) of Income Tax Act and India-Sweden DTAA
Facts of the Case
Corporate
Structure and Business Activity: The Assessee, M/s.
Ericsson Radio Systems A.B. (referred to as "ERA"), is a company
incorporated in Sweden and a 100% subsidiary of Telefon...
Commissioner of Income Tax-XVI vs. Mr. Robert Michael Arthey, Mr. Lestner Garnett, & Mr. Vijay Gopal Jindal: Delhi High Court Ruling on Non-Chargeability of Interest Under Section 234B and Section 234C When Entire Income is Subject to Tax Deducted at Source (TDS) and Appeal Non-Maintainability Due to Low Tax Effect Under CBDT Guidelines
Facts of the CaseThe Commissioner of Income Tax-XVI (Appellant) filed appeals
against several individual assessees, including Mr. Robert Michael Arthey, Mr.
Lestner Garnett, and Mr. Vijay Gopal Jindal. The Assessing Of...