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Director of Income Tax (International Taxation) vs. M/s GE Packaged Power Inc.: Scope of Business Connection Under Section 9(1) of the Income Tax Act and Permanent Establishment Benchmarks
Facts of the CaseThe Revenue (Director of Income Tax International Taxation)
filed a series of Income Tax Appeals (ITA No. 353/2014 and multiple connected
appeals including ITA Nos. 354/2014 to 391/2014 and 402/2014) b...
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...
Director of Income Tax (International Taxation) vs GE Group Entities | Delhi High Court on Permanent Establishment, International Taxation & Taxability of Foreign Enterprises under Income Tax Act
Facts of the Case
The
Revenue filed multiple appeals against different GE group foreign entities
engaged in international business operations connected with India.
The
disputes related to taxation o...
Director of Income Tax (International Taxation) vs GE Group Companies | Delhi High Court on Taxability of Offshore Supply & Permanent Establishment under Income Tax Act and DTAA
Facts of the Case
The
Revenue Department preferred multiple appeals against various foreign GE
entities engaged in supply of equipment, engineering services, power
systems, aircraft engine servi...
Director of Income Tax (International Taxation) vs GE Group Entities | Delhi High Court on Taxability of Offshore Services & Permanent Establishment under Income Tax Act and DTAA | ITA 353/2014 & Connected Matters
Facts of the CaseThe Revenue Department filed multiple appeals before the
Delhi High Court against various GE group entities including GE Packaged Power
Inc., GE Jenbacher GmbH & Co. OHG, GE Nuovo Pignone S.P.A., G...
Director of Income Tax (International Taxation) vs GE Packaged Power Inc. & Connected Matters | Delhi High Court | Section 234B Interest on Non-Residents Where TDS Liability Exists Under Section 195 | 2015:DHC:278-DB
Facts of the CaseThe case involved multiple appeals filed by the Revenue
under Section 260A of the Income Tax Act, 1961 against various General Electric
group entities including GE Packaged Power Inc., GE Jenbacher Gmb...
Commissioner of Income Tax (Central)-III vs M/s Lords Distillery Ltd. | Delhi High Court on Allowability of Business Loss and Deduction Claims under Sections 28, 37(1), 36(1)(vii) & 260A of the Income Tax Act
Facts of the Case
Various
assessees had advanced sums in the ordinary course of business operations.
Certain
advances subsequently became unrecoverable and were claimed as deductions.
The
...
Director of Income Tax (International Taxation) vs GE Group Entities | Delhi High Court on Taxability of Offshore Supply & International Taxation Appeals under the Income Tax Act
Facts of the CaseThe appeals were filed by the Director of Income Tax (International
Taxation) against various GE group entities including GE Packaged Power
Inc., GE Jenbacher GmbH & Co. OHG, GE Nuovo Pignone S.P.A...
Director of Income Tax (International Taxation) vs GE Group Entities | Delhi High Court Upholds Reliance on Earlier Ruling in International Taxation Appeals | Sections 9 & 260A of Income Tax Act
Facts of the CaseThe Director of Income Tax (International Taxation) filed
multiple appeals before the Delhi High Court against several GE group companies
engaged in international business operations involving supply o...
Director of Income Tax (International Taxation) vs GE Group Entities | Delhi High Court Upholds Reference to Earlier Judgment in International Taxation Appeals | Sections 9(1)(i), 44BB & DTAA – Income Tax Act
Facts of the CaseThe Revenue filed several appeals against foreign GE group
entities engaged in activities relating to power, energy, engineering, aircraft
engine services, and industrial operations. The core dispute p...