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Rolls Royce Plc v. Director of Income Tax (International Taxation) – Permanent Establishment (PE) in India through Indian Subsidiary under Article 5 of India–UK DTAA and Taxability of Profits Attributable to PE
Facts of the CaseRolls Royce Plc was incorporated in England and
Wales and was a tax resident of the United Kingdom. It supplied parts and
equipment to Indian customers, including the Indian Navy, Indian Air Force and
...
Commissioner of Income Tax vs Pfizer Limited – Treatment of Balance Written Back, Business Income and Deduction under Section 80HHC | Delhi High Court
Facts of the Case
The assessee had written back certain expenditure liabilities in
its books of account.
The written-back amount represented balances relating to
expenditure incurred in earlier years.
T...
Commissioner of Income Tax vs Visisth Chay Vyapar Ltd. | Interest on Inter-Corporate Deposit (ICD) Not Taxable as Interest on Loan or Advance under Sections 2(7) & 5 of the Interest-tax Act, 1974 | Delhi High Court
Facts of the CaseVisisth Chay Vyapar Ltd. had placed Inter-Corporate
Deposits (ICDs) amounting to ₹22 crores with Shaw Wallace & Company Ltd.
(SWC). The placement of the ICDs was approved through a Board Resoluti...
Rolls Royce PLC vs Director of Income Tax (International Taxation) | Delhi High Court | Permanent Establishment (PE) in India under India–UK DTAA – Attribution of Profits and Business Connection
Facts of the CaseRolls Royce PLC, incorporated in England and Wales
and a tax resident of the United Kingdom, supplied aircraft engines, parts, and
equipment to Indian customers, including the Indian Navy, Indian Air F...
Rolls Royce PLC vs Director of Income Tax (International Taxation) | Delhi High Court | Permanent Establishment in India under Article 5 of India–UK DTAA and Attribution of Profits to PE
Facts of the
CaseRolls Royce PLC, a company incorporated in England
and Wales and a tax resident of the United Kingdom, supplied aircraft and
equipment to Indian customers including the Indian Navy, Indian Air Force a...
Rolls Royce Singapore Pte. Ltd. vs Assistant Director of Income Tax – Dependent Agent Permanent Establishment (PE), Arm’s Length Principle and Taxability of Business Profits under India–Singapore DTAA | Delhi High Court
Facts of the CaseRolls Royce Singapore Pte. Ltd., a company
incorporated in Singapore, was engaged in supplying spare parts, repair
services, maintenance services, and technical support relating to oil-field
equipment...
Commissioner of Income Tax vs. Vasisth Chay Vyapar Ltd. (2011) – Inter-Corporate Deposits (ICDs) Not Taxable as Interest on Loans or Advances under Sections 2(7) & 5 of the Interest Tax Act, 1974
Facts of the CaseThe assessee company, Vasisth Chay Vyapar Ltd.,
placed Inter-Corporate Deposits (ICDs) amounting to ₹22 crores with Shaw
Wallace & Company Ltd. (SWC) after passing a Board Resolution authorizing
...
Rollatainers Ltd. vs Commissioner of Income Tax (Delhi High Court) – Taxability of Waiver of Working Capital Loan under Sections 41(1), 28(iv) and 2(24) of the Income-tax Act, 1961
Facts of the CaseThe assessee, Rollatainers Ltd., was engaged in the
business of manufacturing lined and flexible cartons, packing materials,
automatic packing machines, weighing machines, trading of machinery and spar...
Rolls Royce Plc v. Director of Income Tax (International Taxation) [2011] Delhi High Court – Permanent Establishment (PE) in India, Attribution of Profits under Indo-UK DTAA, Business Connection under Section 9(1)(i), and Taxability of Foreign Enterprises
Facts of the Case
Rolls Royce Plc was incorporated in the United
Kingdom and was a non-resident for Indian tax purposes.
The company supplied aircraft engines, parts,
equipment, and related products to In...
Commissioner of Income Tax v. Assessee Company – Allowability of Insurance Premium Paid for Customers as Business Expenditure under Section 37(1) of the Income Tax Act | Delhi High Court
Facts of the Case
The assessee was engaged in the manufacture and sale of urea.
It introduced an insurance scheme under which every purchaser of a
bag of urea was insured for ₹4,000.
The assessee paid insur...