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Commissioner of Income Tax Vs. Sahara Airlines Ltd. – Whether Payments to Foreign Computerized Reservation System (CRS) Providers for Ticket Booking Software Constitute 'Royalty' or 'Business Income' under Section 195 of the Income Tax Act, 1961 and Relevant DTAA Provisions: Delhi High Court Affirmation on Non-Deduction of TDS

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 75
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Facts of the Case The respondent/assessee, Sahara Airlines Ltd., entered into operational arrangements with two foreign companies: M/s. Amadeus Marketing (a Spanish entity) and M/s. Galileo Internatio...

Gautam Cable Industries vs Deputy Commissioner of Income Tax | Delhi High Court | Disallowance of Interest on Diversion of Borrowed Funds to Sister Concerns | Section 36(1)(iii) of the Income-tax Act, 1961

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 72
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Facts of the CaseThe assessee, Gautam Cable Industries, had claimed deduction of interest paid to banks on borrowed funds. During assessment proceedings, the Assessing Officer found that a portion of the borrowed fund...

Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009) | TDS Liability Under Section 195 on Software Payments to Non-Resident Companies: Whether Ticket Reservation Software Payments Constitute 'Royalty' or 'Business Income' Under DTAA

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 63
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Facts of the Case The respondent/assessee, Sahara Airlines Ltd., entered into commercial arrangements with two international non-resident companies: M/s. Amadeus Marketing (a Spanish company) and M/s....

Spaze Towers (P) Ltd. vs. Commissioner of Income Tax Delhi-III | Withdrawal of Writ Petitions under Article 226

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 67
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Facts of the CaseThe petitioner, Spaze Towers (P) Ltd., filed a series of writ petitions (W.P.(C) 12788/2009, 12794/2009, 12810/2009, 12828/2009, 326/2010, 327/2010, 333/2010, 334/2010, 335/2010, 336/2010) before the...

Commissioner of Income Tax, Delhi vs. Raghav Bahl (Delhi High Court) – Revenue Appeal Dismissed as No Substantial Question of Law Arose under the Income-tax Act

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 59
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Facts of the CaseThe Revenue filed appeals before the Delhi High Court against a common order dated 08.08.2008 passed by the Income Tax Appellate Tribunal in ITA Nos. 3555-3557/Del/2003 relating to Assessment Years 2...

Commissioner of Income Tax vs. Akums Drugs & Pharmaceuticals Ltd. – Allowability of Commission Paid to Agents for Government Institutional Supplies under Section 37(1) of the Income-tax Act, 1961

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 67
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 Facts of the Case The assessee was engaged in the manufacture and supply of pharmaceutical products, including supplies to Government institutions. Commission payments were made to agents for ...

Commissioner of Income Tax vs. Sahara Airlines Ltd. (ITA No. 1170/2009) | Whether Ticket Reservation Software Payments to Foreign Entities (Amadeus & Galileo) Constitute Royalty or Business Income Under Section 195 of Income Tax Act, 1961

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My Tax Expert
11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 74
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Facts of the Case The respondent/assessee, M/s. Sahara Airlines Ltd., entered into operational arrangements with two foreign companies: M/s. Amadeus Marketing (a Spanish company) and M/s. Galileo Inte...

Commissioner of Income Tax vs. Akums Drugs & Pharmaceuticals Ltd. – Deductibility of Commission Paid to Agents for Government Institutional Business under Section 37(1) of the Income-tax Act, 1961

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 42
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Facts of the Case The assessee was engaged in manufacturing pharmaceutical formulations and supplying medicines to Government institutions. Commission payments were made to various agents who assist...

Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009) | Applicability of TDS under Section 195 on Software Payments for Ticket Reservation Systems to Foreign Entities (M/s. Amadeus Marketing & M/s. Galileo International): Royalty vs. Business Income under DTAA

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 28
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Facts of the Case The respondent/assessee, Sahara Airlines Ltd., entered into operational agreements with two foreign entities: M/s. Amadeus Marketing (a Spanish company) and M/s. Galileo Internationa...

Commissioner of Income Tax, Delhi vs Raghav Bahl (Delhi High Court) – No Substantial Question of Law Arises in Revenue Appeal | ITA Nos. 16/2010 & 1188/2009

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11/06/2026  |  0 COMMENTS  |  VISITOR'S COUNT: 37
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Facts of the Case The Income Tax Appellate Tribunal passed a common order dated 08.08.2008 in ITA Nos. 3555-3557/Del/2003 relating to Assessment Years 2000-01, 2001-02 and 2002-03. The Revenue challenged...