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Director of Income Tax vs. M/s SNC Lavalin International Inc. (Delhi High Court) – Taxability of Technical Consultancy Fees under India–Canada DTAA | Interpretation of Article 12(4)(b) – Development and Transfer of Technical Plans/Designs
Facts of the CaseM/s SNC Lavalin International Inc., a non-resident
Canadian company, was engaged in providing consultancy services for
infrastructure projects. The company entered into an agreement with the
National ...
Director of Income Tax vs Various Assessees – No Interest Under Section 234B Where Income is Subject to TDS | Delhi High Court Following DIT v. Mitsubishi Corporation
Facts of the
Case
Multiple appeals were filed by the Income Tax Department against
different assessees.
The sole issue involved in these appeals was the charging of
interest under Section 234B of t...
Commissioner of Income Tax vs. M/s. Bharat Commerce AND Industries LTD. the matter arises under Income Tax Appeal numbers ITA Nos. 1213/2006, 1327/2007, 1329/2007, and 48/2008).
Facts of the Case
Context
of Appeals: The Revenue preferred multiple appeals (ITA
Nos. 1213/2006, 1327/2007, 1329/2007, and 48/2008) against the common
order passed by the Income Tax Appellate Tribuna...
Commissioner of Income Tax-II v. Moonlight Exim Pvt. Ltd. [2010:DHC:4204-DB] – Addition under Section 68 Deleted Where Identity and Creditworthiness of Directors Were Established and Loan Transaction Could Not Be Treated as Non-Genuine on Mere Presumptions
Facts of the
Case
The Assessing Officer made an addition of ₹12,50,000 under Section
68 of the Income Tax Act, 1961 treating the loan received from
directors/shareholders as unexplained cash credit.
Th...
Commissioner of Income Tax-II v. Moonlight Exim Pvt. Ltd. [2010:DHC:4204-DB] – Addition under Section 68 Deleted Where Identity and Creditworthiness of Directors Were Established and Loan Transaction Could Not Be Treated as Non-Genuine on Mere Presumptions
Facts of the
Case
The Assessing Officer made an addition of ₹12,50,000 under Section
68 of the Income Tax Act, 1961 treating the loan received from
directors/shareholders as unexplained cash credit.
Th...
Director of Income Tax vs. Mitsubishi Corporation & Connected Assessees – No Interest under Section 234B Where Income is Subject to TDS | Delhi High Court
Facts of the
Case
The assessees had earned income on which tax was required to be
deducted at source under the provisions of the Income-tax Act.
The Assessing Officer sought to levy interest under Section 234B...
Director of Income Tax vs. M/s Mitsubishi & Connected Assessees – No Interest under Section 234B Where Income is Subject to TDS | Delhi High Court
Facts of the
CaseThe Revenue Department filed multiple appeals
before the Delhi High Court challenging the relief granted to the assessees on
the issue of charging interest under Section 234B of the Income-tax Act, 19...
Commissioner of Income Tax vs. M/s Kishore Apparels [2010] 2010:DHC:4238-DB (Delhi High Court)
Facts of the
Case
The Revenue filed an appeal under Section 260A of the Income Tax
Act, 1961 against the order of the Income Tax Appellate Tribunal for Assessment
Year 2003-04.
The Assessing Officer had ...
Director of Income Tax vs. SNC Lavalin International Inc. – Whether Development and Transfer of Technical Plans Constitutes “Fees for Included Services” under Article 12(4)(b) of the India–Canada DTAA and Taxable at 15%
Facts of the CaseSNC Lavalin International Inc., a non-resident
Canadian company, was engaged in providing consultancy services for
infrastructure projects. The company entered into an agreement with the
National High...
Director of Income Tax vs. Mitsubishi Corporation & Connected Assessees | Section 234B Interest Not Leviable Where Income is Subject to TDS | Delhi High Court
Facts of the
Case
The Revenue preferred multiple appeals before the Delhi High Court.
The sole issue involved in all appeals was the applicability of
interest under Section 234B of the Income Tax Act.
The as...