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Principal Commissioner of Income Tax-7, Delhi vs Qualcomm India Pvt. Ltd. (Delhi High Court) – Exclusion of Comparables & No TP Adjustment on Receivables when Working Capital Adjustment Allowed [Section 92B, Rule 10B]
Facts of the
CaseThe present appeal was filed by the Revenue before
the Delhi High Court against the order dated 19.01.2023 passed by the Income
Tax Appellate Tribunal (ITAT) for Assessment Year (AY) 2014–15. The Re...
Sinogas Management PTE Ltd vs Deputy Commissioner of Income Tax & Anr (Delhi High Court) – Non-Issuance of Draft Assessment Order u/s 144C Renders Assessment Void
Facts of the
Case
The Petitioner, Sinogas Management PTE Ltd, is a
Singapore-based company engaged in operating ships and claimed tax
residency in Singapore.
It filed its return for AY 2017–18 declari...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Deloitte Touche Tohmatsu (Delhi High Court, 2023) – Mutuality Principle vs Fees for Technical Services under Section 260A
Facts of the
CaseThe assessee, Deloitte Touche Tohmatsu (a Verein
registered in Switzerland), is a non-profit association consisting of member
firms across the globe. It filed returns for AYs 2008–09 to 2011–12 de...
Commissioner of Income Tax (International Taxation-1), New Delhi vs Deloitte Touche Tohmatsu – Doctrine of Mutuality vs Fee for Technical Services under Section 260A of Income Tax Act
Facts of the
CaseThe respondent assessee, Deloitte Touche Tohmatsu,
is a Switzerland-based Verein (association) comprising member firms engaged in
professional services globally.
The assessee filed nil income return...
Commissioner of Income Tax (International Taxation-1), New Delhi vs Deloitte Touche Tohmatsu – Doctrine of Mutuality Excludes Subscription Receipts from Taxation (Section 260A, Income Tax Act)
Facts of the
CaseThe respondent/assessee, Deloitte Touche Tohmatsu,
is an association (Verein) established in Switzerland comprising member firms
(chartered accountant entities) across the globe.For Assessment Years 2...
Commissioner of Income Tax, International Taxation–1, New Delhi vs Deloitte Touche Tohmatsu (Delhi High Court) – Mutuality Principle & Taxability of Subscription Receipts under Income Tax Act
Facts of the
Case
The assessee, Deloitte Touche Tohmatsu, is a Swiss Verein
(association) consisting of member firms across the globe.
It filed income tax returns for AY 2008–09 to AY 2011–12 declaring ni...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs Deloitte Touche Tohmatsu | Section 260A | Doctrine of Mutuality | Whether Subscription Receipts Constitute Fees for Technical Services
Facts of the CaseThe respondent assessee, Deloitte Touche Tohmatsu
(Verein), is an association established in Switzerland comprising member firms
across the globe engaged in professional services such as audit, account...
Principal Commissioner of Income Tax-7 vs M/s Pilot Industries Ltd. (Delhi High Court) – Appeal Dismissed as Covered by Earlier Judgments for AY 2010–11
Facts of the
Case
The present appeal was filed by the Revenue concerning Assessment
Year (AY) 2010–11.
The appeal challenged the order dated 23.11.2021 passed by the
Income Tax Appellate Tribunal (ITA...
Pr. Commissioner of Income Tax (Central)-2 vs. Electrical and Electronics India Ltd. | Delhi High Court | Section 69 Income Tax Act | AY 2011-12
Facts of the
Case
The case relates to Assessment Year 2011–12.
The Assessing Officer made an addition of ₹4,25,00,085 under
Section 69 alleging unexplained investments by the assessee in the
JP Mind...
Rishi Ganga Power Corporation Ltd. vs Assistant Commissioner of Income Tax (Delhi High Court, 2023) – Effect of Approved Resolution Plan on Income Tax Demands under IBC
Facts of the
Case
The petitioner, Rishi Ganga Power Corporation Ltd. (RGPCL),
filed its return for AY 2017–18 declaring losses.
During assessment, the Income Tax Department:
Passed an order under Sec...