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Commissioner of Income Tax Vs. [Respondent Party Name] | Maintainability of Tax Appeal Absent COD Approval Under Section 260A of the Income Tax Act, 1961 (2009:DHC:9878-DB)*
Facts of the Case
The Revenue (Income Tax Department) filed an appeal (ITA No.
89/2009) before the Hon’ble High Court of Delhi against an order passed
under the Income Tax Act, 1961.
Along with the appe...
Commissioner of Income Tax vs. Gangour Investment Ltd. – Deletion of Section 68 Share Application Money Addition on Failure of Revenue to Disprove Identity and Creditworthiness of Corporate Investor
Facts of the CaseThe assessee, Gangour Investment Ltd. (a member of
the National Stock Exchange engaged in the purchase and sale of shares), filed
its Income Tax Return for the Assessment Year 1996-97, declaring a loss...
Delhi High Court Ruling on Tax Deductibility of Corporate Club Membership: Commissioner of Income Tax vs. Samtel Color Limited (ITA 1152/2008)
Facts of the CaseThe assessee, M/s Samtel Color Limited, paid
corporate membership fees to India Habitat Centre (₹5 lakhs) and Sports &
Cultural Club, Noida (₹1 lakh), totaling ₹6 lakhs during the assessment ...
Director of Income Tax, New Delhi vs. Sheraton International Inc. — High Court of Delhi Judgement on the Taxability of Composite Fees as Business Profits vs. Royalty and Fees for Included Services under the Indo-USA Double Taxation Avoidance Agreement (DTAA)
Facts of the Case
The
Assessee: Sheraton International Inc. is a
company incorporated in the USA and a non-resident under Indian tax laws,
specializing in providing global hospitality and hotel-relate...
Director of Income Tax, New Delhi vs. Sheraton International Inc.: Whether Composite Fees Received by a Non-Resident for Global Marketing, Publicity, and Centralized Reservation Services Constitute Taxable Royalty/Fees for Included Services or Exempt Business Profits under the Indo-USA DTAA in the Absence of a Permanent Establishment
Facts of the Case
The assessee, Sheraton International Inc., is a company
incorporated in the USA and qualifies as a non-resident under Indian tax
laws. It specializes in providing comprehensive hospitality...
Director of Income Tax, New Delhi vs. Sheraton International Inc.
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a non-resident company incorporated under the laws
of the USA, specializing in providing comprehensive hotel-related
...
Director of Income Tax, New Delhi vs. M/s Sheraton International Inc.: Taxability of Integrated Global Marketing, Advertisement, and Reservation Services Under India-USA DTAA—Whether Receipts Constitute Business Profits in Absence of PE or Taxable as Royalty / Fee for Included Services (FIS) Under Section 9(1) of Income Tax Act, 1961
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a company incorporated in the USA and a
non-resident under Indian tax laws. It is engaged in providing worldwide
...
Commissioner of Income Tax v. Assessee (Name Not Available in Extract) – Appeal Dismissed Due to Low Tax Effect Under CBDT Instruction No. 5/2008 [Delhi High Court]
Facts
of the CaseThe Revenue preferred appeals
before the Delhi High Court under the Income-tax Act, 1961. The matters related
to different assessment years. At the stage of admission, the Court examined
the maintain...
Director of Income Tax, New Delhi vs. M/s Sheraton International Inc.: Whether Composite Fees Received by a Non-Resident Foreign Entity for Global Hotel Marketing, Publicity, and Centralized Reservation Network Services Are Taxable as Royalties/Fees for Included Services or Exempt as Business Profits under Section 9 of the Income Tax Act, 1961 and Articles 7 & 12 of the Indo-US DTAA in the Absence of a Permanent Establishment in India
Facts of the Case
The
Assessee (Sheraton International Inc.) is a company incorporated in the
USA and qualifies as a non-resident under Indian tax laws. It provides
specialized marketing, publicity, a...
Commissioner of Income Tax vs Assessee – Delhi High Court Dismisses Revenue Appeal Due to Low Tax Effect Under CBDT Instruction No. 5/2008 | ITA No. 681/2009
Facts of the
CaseThe Revenue preferred an appeal before the Delhi
High Court under Section 260A of the Income-tax Act, 1961. The matter came up
along with several connected appeals. The Court examined the maintainabil...