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Bombardier Transportation India Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Transfer Pricing – Determination of Arm’s Length Price (ALP) under Income Tax Act
Facts of the
Case
The assessee, Bombardier Transportation India Pvt. Ltd., was
engaged in manufacturing and supplying bogies/wagons to its Associated
Enterprise (AE), Bombardier Transportation GmbH.
The...
Habitat Infracon Private Limited vs Income Tax Officer Ward 11(1), Delhi & Ors. – Reassessment Notice Quashed as Time-Barred under Sections 148 & 148A of Income Tax Act
Facts of the
CaseA notice under Section 148 of the Income Tax Act, 1961 dated 30.06.2021
was allegedly issued.
However, the notice was actually communicated via email only on
16.07.2021.
Subsequent not...
Pr. Commissioner of Income Tax (Central-1) vs Blue Coast Hotels Ltd. – No Disallowance under Section 14A in Absence of Exempt Income (Delhi High Court)
Facts of the
CaseThe appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal dated 17.03.2023 concerning
Assessment Year 2016–17. The Assessing Officer had made a disallowance
amo...
Commissioner of Income Tax (International Taxation)-1 vs A B Sciex Pte Ltd (Delhi High Court) – Permanent Establishment & Arm’s Length Principle Remand Case (AY 2017-18 to 2019-20)
Facts of the
Case
The Revenue filed appeals against orders of the Income Tax
Appellate Tribunal (ITAT) for AY 2017-18, 2018-19, and 2019-20.
The Tribunal had primarily examined whether the assessee had a Perm...
PR. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. & Connected Matters (ITA 329/2022 & Ors.) – Delhi High Court | Appeals Closed Due to CIRP Proceedings
Facts of the
CaseThe present batch of appeals was filed by the
Revenue challenging various orders passed by the Income Tax Appellate Tribunal
(ITAT) concerning multiple assessment years ranging from AY 2010–11 to AY...
Commissioner of Income Tax (International Taxation)-3 vs Zaheer Mauritius | Delhi High Court | Section 2(28A), India-Mauritius DTAA (Articles 11 & 13) | Capital Gains vs Interest on CCDs
Facts of the
Case
The respondent/assessee, Zaheer Mauritius, along with Vatika Pvt.
Ltd., invested in Compulsorily Convertible Debentures (CCDs) issued
by SH Tech Park Developers Pvt. Ltd.
CCDs were iss...
M/s Sahu Exports vs Assistant Commissioner of Income Tax & Anr. (Delhi High Court, 2023) – Reassessment u/s 148 Quashed Due to Lack of Independent Application of Mind
M/s Sahu Exports vs Assistant Commissioner of Income Tax & Anr.
(Delhi High Court, 2023) – Reassessment u/s 148 Quashed Due to Lack of
Independent Application of Mind Facts of the
CaseThe petitioner, M/s Sa...
Commissioner of Income Tax (International Taxation-1) vs DXC Technology Services Singapore Pte. Ltd. (Delhi High Court) – Software Payments Not Royalty under Article 12 of India-Singapore DTAA [ITA 802/2023
Facts of the
CaseThe case pertains to taxation of income received by
the assessee, a Singapore-based entity, from the sale/supply of off-the-shelf
software to various customers in India. During scrutiny assessment, th...
Commissioner of Income Tax (International Taxation)-1 vs A B Sciex Pte. Ltd. (Delhi High Court) – Permanent Establishment & Arm’s Length Pricing Remand Case
Facts of the CaseThe appeals were filed by the Revenue (Commissioner of
Income Tax – International Taxation) challenging orders passed by the Income
Tax Appellate Tribunal for Assessment Years 2017–18, 2018–19, a...
Principal Commissioner of Income Tax vs National Fertilizers Ltd (Delhi High Court) – Jurisdiction, Taxability & Substantial Question of Law under Section 260A
Facts of the
CaseThe appeal was filed by the Revenue before the
Delhi High Court under Section 260A of the Income Tax Act, 1961 against the
order of the Income Tax Appellate Tribunal (ITAT). The dispute arose from
as...