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Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Delhi High Court on Taxability of Customized Software Payments as Royalty under Section 9(1)(vi), Article 12 of Indo-US DTAA & Interest under Section 234B
Facts of the CaseThe Revenue filed multiple appeals under Section 260A of the
Income Tax Act against the order of the Income Tax Appellate Tribunal (ITAT)
concerning various assessment years. The dispute pertaine...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (CIT) — Delay in Re-filing Income Tax Appeals Not Condoned | Delhi High Court | Section 260A of the Income-tax Act, 1961
Facts of the
Case
The appellant, Eastern India Powertech Ltd., had filed
several Income Tax Appeals before the Delhi High Court.
The appeals were originally instituted in April 2013 within
the prescribe...
Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Whether Consideration for Supply of Customized Software Constitutes Royalty under Section 9(1)(vi) and Article 12 of Indo-US DTAA | Delhi High Court
Facts of the CaseThe Revenue filed appeals under Section 260A challenging the
order of the Income Tax Appellate Tribunal (ITAT) for multiple assessment
years. The dispute arose regarding payments received by Aspect Sof...
Commissioner of Income Tax (International Taxation)-3 vs Travelport L.P. USA | Delhi High Court on Remand of International Tax Appeals for AY 2009–10 & 2010–11 under Income Tax Act
Facts of the CaseThe Revenue preferred appeals before the Delhi High Court
challenging the ITAT’s order dated 19 September 2016 in respect of Assessment
Years 2009–10 and 2010–11.It was brought to the Court’s a...
Commissioner of Income Tax (International Taxation)-3 vs Travelport L.P. USA | Delhi High Court on Remand of International Tax Appeals under Income Tax Act (AY 2009-10 & 2010-11)
Facts of the CaseThe Revenue preferred appeals before the Delhi High Court
against the orders of the Income Tax Appellate Tribunal dated 19 September 2016
concerning Assessment Years 2009-10 and 2010-11. The respondent...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (Delhi High Court) – Condonation of 960 Days Delay in Re-filing Income Tax Appeals Rejected
Facts of the
CaseThe appellant, Eastern India Powertech Ltd., had
originally filed multiple income tax appeals in April 2013 under Section 260A
of the Income Tax Act. The appeals were returned with procedural objectio...
Pr. Commissioner of Income Tax-10 vs Continental Foundation Joint Venture | Delhi High Court on Deductibility of Bank Guarantee Commission from FDR Interest and Section 80HHBA Deduction
Facts of the CaseThe Revenue preferred appeals against the common order of the
Income Tax Appellate Tribunal (ITAT) concerning Assessment Years 2002-03 and
2003-04. The dispute primarily centered around the treatment o...
Oriental Insurance Company Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Scope of Proviso to Section 220(1) of Income Tax Act, 1961 for Curtailment of Statutory 30 Days’ Demand Period in Penalty Proceedings under Section 271(1)(c)
Facts of the
CaseThe Petitioner, Oriental Insurance Company Ltd.,
challenged an impugned notice dated 15.03.2017 issued by the Revenue whereby
the statutory period of 30 days for payment of tax demand under Sect...
Pr. Commissioner of Income Tax-08 vs Staunch Marketing Pvt. Ltd. | Mandatory Notice under Section 143(2) in Reassessment Proceedings under Sections 148/144 of Income Tax Act, 1961 | Delhi High Court
Facts of the CaseThe Revenue filed an appeal under Section 260A challenging the
Income Tax Appellate Tribunal’s order relating to Assessment Year 2003-04. The
Assessing Officer had initiated reassessment proceedings ...
Principal Commissioner of Income Tax, Delhi-2 vs Copal Research India Pvt. Ltd. | Delhi High Court on Transfer Pricing Comparables and ALP Determination under Section 260A of the Income Tax Act
Facts of the Case
The assessee, Copal Research India Pvt. Ltd., was subjected to
transfer pricing assessment in relation to its international transactions.
During assessment proceedings, the Transfer Pricing O...