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Commissioner of Income Tax (International Taxation)-2 vs LS Cable & Systems Ltd Korea (Formerly LS Cable Ltd) | Delhi High Court on Taxability of Offshore Supply under Section 9(1)(i) of the Income-tax Act and India-Korea DTAA
Facts of the CaseThe Revenue filed writ petitions challenging the common order
dated 9 May 2016 passed by the Authority for Advance Ruling (Income Tax),
whereby the applications filed by LS Cable & Systems Lt...
Principal Commissioner of Income Tax-07 vs Oriental Bank of Commerce | Section 14A r/w Rule 8D Disallowance on Exempt Income – Delhi High Court
Facts of the CaseThe Revenue preferred appeals before the Delhi
High Court challenging the common order of the Income Tax Appellate Tribunal
(ITAT) for Assessment Years 2008–09 and 2009–10. The dispute arose from t...
Principal Commissioner of Income Tax (Central)-1 vs Manoj Hora | Delhi High Court | Penalty under Section 140A(3) and Section 221(1) of the Income Tax Act, 1961
Facts of the
CaseThe Revenue preferred two appeals before the Delhi
High Court against the common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Year 2009-10. The ITAT had set aside the...
Principal Commissioner of Income Tax (Central)-1 vs Sahara India Financial Corporation Ltd. | Delhi High Court | Revenue Appeals under Section 260A of the Income Tax Act Dismissed Against ITAT Order on Cross-Objections
Facts of the CaseThe Revenue preferred multiple appeals before the Delhi High
Court under Section 260A of the Income Tax Act, 1961 challenging the order
dated 13 December 2016 passed by the Income Tax Appellate Tribuna...
Commissioner of Income Tax (International Taxation)-2 vs Net App B.V. | Delhi High Court on Taxability of Software Subscription Receipts as Royalty under Section 9(1)(vii) and Interest Liability under Section 234B
Facts of the CaseThe assessee, Net App B.V., earned income from
sale of software and subscription services for Assessment Years 2008-09 and
2010-11. The Revenue treated these receipts as royalty income taxable in India...
Director of Income Tax vs. Mitsui & Co. Ltd. (Delhi High Court) – Liaison Office, Permanent Establishment (PE) under India-Japan DTAA and Taxability of Business Income under Sections 9(1), 44BBB & 260A of the Income Tax Act, 1961
Facts of the Case
Mitsui
& Co. Ltd., a Japanese company, was a non-resident entity having its
headquarters in Japan.
The
Assessee had undertaken two projects in India:
Anpara
...
Director of Income Tax vs Mitsui & Co. Ltd. | Delhi High Court on Permanent Establishment under India-Japan DTAA, Taxability of Liaison Office & Section 44BBB of Income Tax Act
Facts of the CaseMitsui & Co. Ltd., a non-resident company incorporated in
Japan, had established a Liaison Office (LO) in India with RBI approval. The
company was executing two power-related projects in Indi...
Commissioner of Income Tax (International Taxation)-2 vs Net App B.V. – Taxability of Software Subscription Receipts as Royalty under Section 9(1)(vi) of the Income Tax Act read with Article 12 of India-Netherlands DTAA | Section 234B Interest Liability
Facts of the CaseThe present matter arose from two appeals filed by
the Revenue before the Delhi High Court against the order of the Income Tax
Appellate Tribunal (ITAT) concerning Assessment Years 2008-09 and 20...
Principal Commissioner of Income Tax–7 vs. Bikram Singh | Delhi High Court | Section 68 of the Income-tax Act, 1961 | Unexplained Cash Credits, Identity, Creditworthiness & Genuineness of Loan Transactions
Facts of the CaseThe assessee filed his income tax return for Assessment Year
2011–12 declaring income of ₹80,45,590.During assessment proceedings, the Assessing Officer noticed
unsecured loans/advances aggregating...
Pr. Commissioner of Income Tax-06 vs Modi Apollo International Group (P) Ltd. | Delhi High Court on Section 195 TDS, Fee for Technical Services (FTS) & Royalty Payment under Income Tax Act
Facts of the
CaseThe Revenue preferred appeals against the common
order passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2007-08 and 2009-10.The assessee had made payments to Apollo
Internation...