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The Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd. (2007) | ITA No. 785 of 2006 (Consolidated with ITA No. 641 of 2006) – Delhi High Court Judgement on Section 80IA Manufacture Qualification for Software Duplication and Section 40(a)(i) Deferral Allowability upon TDS Payment
Facts of the Case
The
Assessee, M/s Oracle Software India Ltd., is a 100% subsidiary of Oracle
Corporation, USA. It is engaged in developing, designing, marketing, and
importing computer software.
...
Commissioner of Income Tax, Delhi-XVII vs Prasar Bharti (Broadcasting Corporation of India) – TDS on Television Programme Production Payments: Section 194C vs Section 194J | Delhi High Court
Facts of the
CaseThe respondent, Prasar Bharti (Broadcasting
Corporation of India), made payments to producers engaged for producing
television programmes under the “commissioned category.” While making such
paym...
Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd. (2007) | Interpretation of Section 40(a)(i) Royalty Expenses with Pre-Year Tax Deductions at Source (TDS) and Duplication of Software Master Copies as Eligible Manufacturing Activity under Section 80-IA of the Income Tax Act, 1961: A Comprehensive Case Brief on Corporate Deductions and Fiscal Compliance Precedents
Facts of the Case
Corporate
Structure: The Respondent/Assessee (M/s Oracle Software
India Ltd.) is a 100% wholly-owned subsidiary of Oracle Corporation, USA.
It was incorporated to develop, produce, m...
The Commissioner of Income Tax-V vs. M/s Oracle Software India Ltd.: High Court of Delhi on Section 40(a)(i) Tax Deduction at Source (TDS) Compliance Timelines and Section 80IA Deductions for Software Duplication as a Manufacturing Activity
Facts of the Case
The
Respondent/Assessee (M/s Oracle Software India Ltd.) is a 100%
subsidiary of Oracle Corporation, USA, engaged in developing, designing,
producing, marketing, distributing, and im...
CIT vs. M/s Oracle Software India Ltd.: Section 40(a)(i) Disallowance on Software Royalty & TDS Compliance Timeline under Income Tax Act — Delhi High Court Landmark Analysis (ITA No. 811 of 2006 | 2007:DHC:459-DB)
Facts of the Case
Corporate
Structure: The Respondent-Assessee (M/s Oracle Software
India Ltd.) operates as a 100% wholly-owned subsidiary of Oracle
Corporation, USA. It was incorporated to develop, p...
Society for the Advancement of Education Cambridge School Vs. Income Tax Officer (Exemption) | Legal Prerogative and Procedural Implications of the Unconditional Withdrawal of a Writ Petition Under Article 226 of the Constitution of India in Matters Pertaining to Statutory Tax Exemptions for Educational Institutions Under the Income Tax Act, 1961
Facts of the Case
Status
of the Petitioner: The Petitioner is the "Society for
the Advancement of Education Cambridge School," an educational
society managing a network of reputed educational institut...
Director of Income Tax (International Taxation) vs United Airlines (2006) – Validity of Assessment under Section 142(1)(i), Limitation Challenge and Remand to ITAT after Retrospective Amendment
Facts of the
CaseThe Revenue, through the Director of Income Tax
(International Taxation), filed an appeal before the Delhi High Court against
the order of the Income Tax Appellate Tribunal (ITAT) in favour of United
...
Commissioner of Income Tax versus Getit Infomediary Limited: Judicial Interpretation of Deduction for Bad Debts Under Section 36 1 vii of the Income Tax Act 1961
Facts of the CaseThe assessee claimed a deduction of 1,67,33,202 rupees as bad
debts written off during the assessment year 2003 2004. This amount comprised
debts owed by government telephone departments and priv...
S.N.P. Punj v. Deputy Commissioner of Income Tax, Maya Rani Punj & Ors. v. Deputy Commissioner of Income Tax and N.P. Punj v. Roshan Sahay, Deputy Commissioner of Income Tax – Prosecution under Sections 276CC, 276D and 278B of the Income-tax Act Quashed for Lack of Specific Allegations Regarding Responsibility for Conduct of Business
Facts of the CaseThe Income Tax Department instituted a criminal
complaint against M/s Dayagen and its partners for Assessment Year 1988-89
alleging failure to file the return of income within the prescribed period and...
Commissioner of Income Tax versus Smt. Nilofer I. Singh: Interpretation of Full Value of Consideration and Bad Debts Deduction under the Income Tax Act 1961
Facts of the CaseThe assessee sold two properties, one in Mumbai and one in
Delhi, and disclosed capital gains based on the actual sale consideration.
During assessment proceedings under Section 143 3, the Assessing Of...