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Director of Income Tax vs. Ericsson Radio System A.B. (2011) – Taxability of Cross-Border Turnkey Telecommunication Equipment and Software Supplies Under Section 9(1) of Income Tax Act and India-Sweden DTAA
Facts of the Case
The
Assessee: M/s. Ericsson Radio Systems A.B. (ERA) is a
resident corporate entity incorporated under the laws of Sweden and a 100%
subsidiary of Telefonakitiebolaget L.M. Ericsson ...
Director of Income Tax vs. Ericsson Radio System A.B. (2011:DHC:12090-DB) | Taxability of Offshore Supply of Telecommunication Hardware and Embedded Software under Section 9(1) of Income Tax Act and India-Sweden DTAA
Facts of the Case
Corporate
Structure and Business Activity: The Assessee, M/s.
Ericsson Radio Systems A.B. (referred to as "ERA"), is a company
incorporated in Sweden and a 100% subsidiary of Telefon...
Commissioner of Income Tax-XVI vs. Mr. Robert Michael Arthey, Mr. Lestner Garnett, & Mr. Vijay Gopal Jindal: Delhi High Court Ruling on Non-Chargeability of Interest Under Section 234B and Section 234C When Entire Income is Subject to Tax Deducted at Source (TDS) and Appeal Non-Maintainability Due to Low Tax Effect Under CBDT Guidelines
Facts of the CaseThe Commissioner of Income Tax-XVI (Appellant) filed appeals
against several individual assessees, including Mr. Robert Michael Arthey, Mr.
Lestner Garnett, and Mr. Vijay Gopal Jindal. The Assessing Of...
Commissioner of Income Tax-II vs. Kamdhenu Steel & Alloys Ltd. – Section 68, Unexplained Share Application Money, Burden of Proof, Discharge of Initial Onus
Facts of the
CaseThe appeals pertain to multiple assessment years
under the Income Tax Act, 1961, involving additions made by Assessing Officers
under Section 68 on account of unexplained share application money
rece...
Commissioner of Income Tax-III vs Sham Mohan Pvt. Ltd. | Section 68, Income Tax Act, 1961 – Unexplained Share Application Money
Fact of the CaseThe present appeals arose from multiple Income Tax
Appellate Tribunal (ITAT) orders where the Assessing Officer (AO) made
additions under Section 68 of the Income Tax Act, 1961 for unexplained
share ap...
Commissioner of Income Tax-XVI vs Lestner Garnett & Vijay Gopal Jindal | High Court of Delhi | Section 234B & C | ITA 337/2007, 338/2007, 131/2009
Facts of the
Case:The Commissioner of Income Tax-XVI (Appellant)
filed appeals against Mr. Lestner Garnett and Mr. Vijay Gopal Jindal
(Respondents) concerning the levy of interest under Sections 234B and 234C of
the ...
Commissioner of Income Tax vs Kamdhenu Steel & Alloys Ltd. – Analysis under Section 68 of the Income Tax Act, 1961 on Unexplained Share Application Money
Facts of the
Case:The Delhi High Court heard multiple appeals
concerning the additions made by the Assessing Officer (AO) under Section 68
of the Income Tax Act, 1961, on account of unexplained share application
mone...
Commissioner of Income Tax vs. Kamdhenu Steel & Alloys Ltd. & Connected Matters – Addition under Section 68 on Share Application Money Deleted where Identity, Genuineness and Creditworthiness Established | Delhi High Court
Facts of the
CaseThe assessees had received share application money
from various corporate entities through banking channels. During assessment
proceedings, the assessees furnished details including names and addresse...
Director of Income Tax vs. M/s Ericsson Radio System A.B. — Taxability of Offshore Telecom Supplies and Embedded Software as Sale of Goods vs. Royalty under Sections 9(1)(i) and 9(1)(vi) of the Income-Tax Act, 1961
Facts of the CaseThe assessee, M/s. Ericsson Radio Systems A.B. (Sweden), is a
non-resident tax entity that entered into supply, installation, and overall
contracts with multiple Indian cellular operators to execute tu...
Director of Income Tax vs. M/s Ericsson Radio System A.B. — Taxability of Offshore Telecom Supplies and Embedded Software as Sale of Goods vs. Royalty under Sections 9(1)(i) and 9(1)(vi) of the Income-Tax Act, 1961
Facts of the CaseThe assessee, M/s. Ericsson Radio Systems A.B. (Sweden), is a
non-resident tax entity that entered into supply, installation, and overall
contracts with multiple Indian cellular operators to execute tu...