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Commissioner of Income Tax (International Taxation) vs Nortel Network Singapore Pte Ltd (2018) – No Permanent Establishment & Software Payment Not Royalty under India-Singapore DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A challenging
the findings in favour of Nortel Network Singapore Pte Ltd regarding taxability
issues. The primary contention was that the respondent had a Pe...
PR. Commissioner of Income Tax Delhi-2 vs Blue Scope Steel India Pvt. Ltd. (2019) – Delhi High Court | Transfer Pricing | Section 92CA & 260A | Salary Reimbursement to AE
Facts of the CaseThe present appeals were filed by the Revenue
under Section 260A of the Income Tax Act, 1961 before the Delhi High Court for
Assessment Years 2007-08, 2008-09, and 2009-10. The respondent-assesse...
Pr. Commissioner of Income Tax-3 vs DU Securities Pvt. Ltd. (Delhi High Court) – Accommodation Entries Commission Rate Reduced to 0.5% | No Substantial Question of Law
Facts of the Case
The
Revenue filed appeals against a common order passed by the ITAT concerning
multiple assessment years (2005–06, 2006–07, 2007–08, and 2009–10).
The
Assessing Officer ha...
IHHR Hospitality Pvt. Ltd. vs Additional Commissioner of Income Tax (2019) – Reassessment u/s 147/148 Invalid Without Fresh Tangible Material | Delhi High Court
Facts of the CaseAs per the judgment :
The
petitioner, engaged in the hospitality business, filed its return
declaring losses of ₹76.94 crores for AY 2011–12.
The
case was selected for scrutiny...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd | Delhi High Court | Section 260A | Permanent Establishment & Royalty under DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A of the
Income Tax Act, 1961 against Nortel Networks Singapore Pte Ltd. The dispute
pertained to:
Whether the assessee constituted a Permanent Establishme...
PR Commissioner of Income Tax-6, New Delhi vs N.R. Portfolio Pvt. Ltd. (2019) – Doctrine of Merger, Finality & ITAT Rectification Powers under Sections 254(2), 154 & 147/148 Explained
Facts of
the Case
The
assessee (N.R. Portfolio Pvt. Ltd.) was subjected to reassessment
proceedings under Sections 147/148.
The
Assessing Officer made additions under Section 68.
CIT(A):...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd (2018) – Delhi High Court | Section 260A | Permanent Establishment & Royalty under India–Singapore DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A
challenging the taxability of income earned by Nortel Networks Singapore Pte
Ltd.The dispute primarily revolved around:
Whether the assessee had a Perman...
Principal Commissioner of Income Tax, Central-3 vs Abhisar Buildwell Pvt. Ltd. – No Addition under Section 153A Without Incriminating Material | Delhi High Court
Facts of the CaseA search operation was conducted on 21st January 2011 in the
Dharampal Satyapal Group. Consequent to the search, notice under Section 153A
was issued to the assessee, Abhisar Buildwell Pvt. Ltd., which...
Commissioner of Income Tax (International Taxation) vs Nortel Network Singapore Pte Ltd – No Permanent Establishment & Software Payment Not Royalty under India–Singapore DTAA (Section 260A, Income Tax Act, 1961)
Facts of the
CaseThe Revenue filed appeals before the Delhi High
Court under Section 260A of the Income Tax Act challenging the findings in
favor of Nortel Network Singapore Pte Ltd. The core dispute revolved around
...
Ashok Jaipuria vs Tejinder Kumar, ACIT (Income Tax Department) | Delhi High Court | Sections 276C(1) & 277 Income Tax Act | Additional Evidence in Criminal Prosecution
Facts of the Case
The
respondent (Income Tax Department) filed a complaint under Sections
276C(1) and 277 of the Income Tax Act regarding undisclosed foreign bank
accounts of the petitioner.
...