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Legal Analysis: Tax Deduction Obligations on Payments to Non-Residents under Section 195(1) of the Income Tax Act
Facts of the CaseThe appellant, the Director of Income Tax (International
Taxation), initiated these appeals to challenge the orders previously passed by
the lower tax authorities regarding the respondents. The respond...
Director of Income Tax vs. GE Packaged Power Inc.: Judicial Interpretation of Section 195 TDS Obligations
Facts of the CaseThe Appellant, representing the Income Tax Department,
challenged earlier appellate orders that had ruled in favor of various
GE-affiliated entities, including GE Packaged Power Inc., GE Jenbacher GMBH...
Director of Income Tax, International Taxation v. M/s GE Packaged Power Inc. (and Connected Matters): Core Determinations on Permanent Establishment and Deemed Income Accrual Under Section 9(1) of the Income-tax Act, 1961
Facts of the CaseThe Income Tax Department, via the Director of Income Tax,
International Taxation, preferred a massive, consolidated batch of income tax
appeals before the Division Bench of the Hon’ble High Court of...
Commissioner of Income Tax (Central) v. Mohan Meakins Ltd., Saraya Industries Ltd., Superior Industries Ltd. & Others | Delhi High Court | ITA Nos. 430–433/2013 & Connected Appeals
Facts of the Case
Multiple
Income Tax Appeals were filed before the Delhi High Court by the
Commissioner of Income Tax against different assessees.
The
appeals involved similar legal and factual qu...
Director of Income Tax vs. M/s GE Packaged Power Inc. | Section 260A of the Income-tax Act, 1961
Facts of the CaseThe Revenue (Director of Income Tax, International Taxation)
filed a batch of interconnected cross-appeals directed against various foreign
entities belonging to the General Electric (GE) group. ...
Commissioner of Income Tax v. Saraya Industries Ltd. | Delhi High Court | Section 260A Income Tax Act | Deduction of Business Expenditure and Revenue Appeal Principles
Facts of the Case
The
Revenue preferred an appeal before the Delhi High Court challenging the
order passed in favour of the assessee.
The
appeal formed part of a group of connected income tax appea...
Income Tax Appeals on Permanent Establishment under Section 9(1)(i): Director of Income Tax v. M/S GE Packaged Power Inc.
Facts of the CaseThe Revenue (Director of Income Tax, International Taxation)
preferred a massive multi-case batch of income tax appeals against various
foreign entities operating under the corporate umbrella of the Ge...
Director of Income Tax (International Taxation) vs. M/s GE Packaged Power Inc. & Connected Matters: Principles of Permanent Establishment Under Section 9(1)(i) of the Income-tax Act
Facts of the CaseThe Revenue (Director of Income Tax, International Taxation)
filed a batch of income tax appeals (ITA No. 353/2014 and connected matters)
before the High Court of Delhi against various General Electric...
Director of Income Tax, International Taxation vs. M/S GE Packaged Power Inc. & Ors. (2015) | Cross-Border Corporate Taxation & Categorization of Structural Revenue Under Section 260A of Income Tax Act
Facts of the CaseThe Revenue (represented by the Director of Income Tax,
International Taxation) instituted a massive batch of income tax appeals under
Section 260A, structurally cataloged under lead matter ITA No. 353...
Director of Income Tax, International Taxation vs. M/s GE Packaged Power Inc. (and connected matters) under Section 260A of the Income-tax Act, 1961
Facts of the CaseThe Revenue (represented by the Director of Income Tax,
International Taxation) preferred a massive batch of forty income tax appeals
before the Delhi High Court. This consolidated litigation roped in ...