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Director of Income Tax vs. Galileo International Inc. | Delhi High Court on Taxability of CRS Booking Revenue, Permanent Establishment (PE) and Attribution of Profits in India under Sections 5(2) & 9(1)(i) of the Income-tax Act
Facts of the CaseGalileo International Inc., a company incorporated in the
United States and a tax resident of the USA, operated a Computerized
Reservation System (CRS) providing electronic global distribution services...
Director of Income Tax vs. Galileo International Inc. | Delhi High Court | Permanent Establishment (PE), Business Connection & Attribution of Income from CRS Operations in India under Sections 5(2) and 9(1)(i) of the Income-tax Act
Facts of the CaseGalileo International Inc., a company incorporated in the
United States and a tax resident of the USA, operated a Computerized
Reservation System (CRS) that facilitated electronic global distribution
...
Indian Oil Panipat Power Consortium Ltd. v. Income Tax Officer [2009] 315 ITR 255 (Delhi HC) | Interest Earned on Share Capital Temporarily Parked Before Commencement of Business Held as Capital Receipt – Section 56 & Section 260A of the Income-tax Act, 1961
Facts of the
CaseIndian Oil
Panipat Power Consortium Ltd. was incorporated pursuant to a joint venture
between Indian Oil Corporation and Marubeni Corporation, Japan, for
establishing a power project in Panipat, Hary...
Indian Oil Panipat Power Consortium Ltd. vs Income Tax Officer – Interest Earned on Share Capital During Pre-Commencement Period Held as Capital Receipt | Delhi High Court
Facts of the Case
Indian
Oil Panipat Power Consortium Ltd. was incorporated on 06.10.1999 as a
joint venture between Indian Oil Corporation and Marubeni Corporation,
Japan.
The
company was est...
[Petitioner] vs Revenue Department – Delhi High Court | W.P.(C) No. 747/2009 | Interim Protection Against Coercive Recovery of Tax Pending Disposal of Applications
Facts of the Case
The
petitioner approached the Delhi High Court by way of a writ petition concerning
tax recovery proceedings.
The
dispute related to recovery action initiated pursuant to an order ...
Commissioner of Income Tax, Delhi-V vs M/s Pradeep Holdings Pvt. Ltd. – Allowability of Interest on Borrowed Funds Used for Purchase of Shares Held as Stock-in-Trade under Section 36(1)(iii) of the Income-tax Act, 1961 | Delhi High Court
Facts of the CaseThe Revenue filed appeals under Section 260A of the
Income-tax Act, 1961 against the common order of the Income Tax Appellate
Tribunal relating to Assessment Years 2001-02, 2002-03 and 2003-04.The disp...
Commissioner of Income Tax, Delhi-V vs. M/s Pradeep Holdings Pvt. Ltd. (2009) – Interest on Borrowed Funds Used for Share Trading Allowed as Business Expenditure Under Section 36(1)(iii) of the Income-tax Act
Facts of the
CaseThe Revenue
preferred appeals under Section 260A of the Income-tax Act against a common
order of the Income Tax Appellate Tribunal relating to Assessment Years
2001-02, 2002-03, and 2003-04.The asses...
Commissioner of Income Tax, Delhi-II v. Anand Prakash & Maha Maya General Finance Ltd. (2009) – Whether Interest under Section 234B Can Be Levied on Interest Received Subsequently on Enhanced Land Acquisition Compensation
Facts of the CaseThe assessees, Anand Prakash and Maha Maya General Finance
Ltd., owned land acquired by the Government under the Land Acquisition Act,
1894. Initially, compensation was awarded, but the assessees sough...
Commissioner of Income Tax, Delhi-II vs. Anand Prakash & Maha Maya General Finance Ltd. | Section 234B Interest on Enhanced Land Acquisition Compensation – Delhi High Court
Facts of the Case
The
land belonging to the assessee, Anand Prakash, was acquired by the
Government of Haryana in March 1989 under the Land Acquisition Act, 1894.
Dissatisfied
with the original comp...
Commissioner of Income Tax, Delhi-II vs Anand Prakash & Maha Maya General Finance Ltd. (2009) – Levy of Interest under Section 234B on Enhanced Land Acquisition Compensation Interest Receipts
Facts of the CaseThe lands belonging to the assessees were acquired by the
Government of Haryana under the Land Acquisition Act. Initially, compensation
was awarded, but the assessees sought enhancement before the Addi...