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Director of Income Tax vs Guy Carpenter & Co. Ltd. – Reinsurance Brokerage not Taxable as Fees for Technical Services under Section 9(1)(vii) and Article 13 of India-UK DTAA | Delhi High Court
Facts of the CaseThe assessee, Guy Carpenter & Co. Ltd., a
United Kingdom based reinsurance intermediary and broker, received
brokerage/commission from insurance companies operating in India for
facilitating reins...
Krishak Bharati Cooperative Ltd. vs Joint Commissioner of Income Tax & Commissioner of Income Tax Special Range-12 | Delhi High Court | ITA 1278/2007 & ITA 956/2008 | No Substantial Question of Law Arises
Facts of the
CaseKrishak Bharati Cooperative Ltd. filed two income
tax appeals before the Delhi High Court challenging the orders passed by the
Income Tax Authorities. The appeals were registered as ITA No. 1278/2007 ...
Krishak Bharati Cooperative Ltd. vs Joint Commissioner of Income Tax & Commissioner of Income Tax Special Range-12 | Delhi High Court | ITA 1278/2007 & ITA 956/2008 | No Substantial Question of Law Arises
Facts of the
CaseKrishak Bharati Cooperative Ltd. filed two income
tax appeals before the Delhi High Court challenging the orders passed by the
Income Tax Authorities. The appeals were registered as ITA No. 1278/2007 ...
Director of Income Tax vs. Cargill Financial Services Asia Pvt. Ltd. | Delhi High Court on Bill Discounting Charges and TDS Liability under Section 194A of the Income Tax Act
Facts of the CaseCargill Global Trading Pvt. Ltd. had entered into
transactions involving bill discounting arrangements with Cargill Financial
Services Asia Pvt. Ltd. The Assessing Officer treated the bill discou...
Commissioner of Income Tax vs. Shri Anant Jain – Taxability of Retirement Benefits Received Outside India by a “Not Ordinarily Resident” Assessee under Sections 5(1)(c), 6 & 9(1)(ii) of the Income Tax Act, 1961
Facts of the
CaseThe assessee, Shri Anant Jain, had worked with
Enron Corporation, USA from 1991 till November 1999 and during that period he
was a non-resident Indian. Upon termination of his employment, he received
...
A.G. Holdings Pvt. Ltd. vs Income Tax Officer – Reopening of Assessment under Sections 147 & 148 on Alleged Accommodation Entries | Delhi High Court
Facts of the
CaseThe petitioner company filed its return of income
for Assessment Year 2004-05 declaring a loss. The return was processed under
Section 143(1) of the Income Tax Act.Subsequently, the Assessing Officer ...
Commissioner of Income Tax vs. Sahara India Housing Corporation Ltd. | Treatment of Income from Sale & Purchase of Securities – Capital Gains vs Business Income under Sections 14A & 45 of the Income Tax Act
Facts of the CaseThe assessee, Sahara India Housing Corporation
Ltd., had shown gains and losses arising from sale and purchase of securities
under the head “Capital Gains” in its income tax returns for the relevan...
Commissioner of Income Tax vs Promain Ltd. – Validity of Search Warrant under Section 132 and Scope of Block Assessment under Sections 158BC & 158BD of the Income Tax Act, 1961 | Delhi High Court
Facts of the
CaseA search and seizure operation under Section 132 of
the Income Tax Act, 1961 was conducted on 21.11.1996 in relation to the
Hindustan Development Corporation (HDC) Group. Pursuant to the said search, ...
Aditya Khanna vs Assistant Commissioner of Income Tax | Reassessment under Sections 147 & 148 of Income Tax Act in Oil-for-Food Programme Matter – Delhi High Court
Facts of the CaseThe petitioner, Aditya Khanna, was a non-resident
individual who had filed his income tax return for Assessment Year 2002-03
declaring only property income and interest income. The return was processed...
Director of Income Tax (Exemption) vs National Association of Software and Services Companies (NASSCOM) – Delhi High Court | Section 11(1)(a), Section 28(iii), Section 12A & Section 260A of Income Tax Act | Application of Income Outside India, VDIS Tax Payment & Taxability of Membership Subscription
Facts of the CaseThe respondent-assessee, National Association of
Software and Services Companies (NASSCOM), was a trust registered under Section
12A of the Income Tax Act. The Revenue filed multiple appeals before the...