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Commissioner of Income Tax (International Taxation)-3 vs Travelport Global Distribution System B.V. (Delhi High Court) – No Substantial Question of Law on Profit Attribution to Indian Operations
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order dated 13.10.2021 passed by the
Income Tax Appellate Tribunal (ITAT).The dispute pertained to the attribution o...
Chief Commissioner of Income Tax (Central-1) vs Vishnu Apartments Pvt. Ltd. – Delhi High Court | Section 143(3) | Deletion of Addition on Alleged Sham Collaboration Agreement
Facts of the
CaseThe present appeal pertains to Assessment Year
2010–11, wherein the Revenue challenged the order dated 30.01.2020 passed
by the Income Tax Appellate Tribunal.The core issue arises from a collaborati...
GoDaddy.com LLC vs Assistant Commissioner of Income Tax | Delhi High Court | Domain Registration Fees Not Royalty u/s 9(1)(vi)
Facts of the
Case
The assessee, GoDaddy.com LLC, is a US-based company engaged in
domain registration, web hosting, and web design services.
The Assessing Officer treated income received from domain name
...
PepsiCo India Holdings Pvt. Ltd. vs Assessment Unit, Income Tax Department (Delhi High Court) – Final Assessment Order Set Aside for Violation of Section 144C Procedure
Facts of the
CaseThe petitioner, PepsiCo India Holdings Pvt. Ltd.,
challenged the final assessment order dated 21.11.2023 passed by the Assessment
Unit under Section 143(3) read with Section 144C(4) for AY 2020–21. ...
Principal Commissioner of Income Tax vs B.L. Kashyap and Sons Ltd (Delhi High Court) – Section 142(2A), 142(2C) & 292B – Validity of Extension of Time for Special Audit
Facts of the
CaseThe present appeals were filed by the Revenue
challenging a common order passed by the Income Tax Appellate Tribunal
concerning multiple assessment years (AY 2004–05 to AY 2008–09).The core issue ...
P.R. Commissioner of Income Tax (Central-02) vs B.L. Kashyap and Sons Ltd. | Section 142(2A), 142(2C), 292B Income Tax Act – Delhi High Court
Facts of the
CaseThe appeals were filed by the Revenue before the
Delhi High Court challenging a common order dated 30.09.2020 passed by the
Income Tax Appellate Tribunal concerning Assessment Years 2004–05 to 2008â...
P.R. Commissioner of Income Tax (Central) vs B.L. Kashyap and Sons Ltd. | Section 142(2A), 142(2C), 292B – Delhi High Court Judgment (2023)
Facts of the
CaseThe appeals were filed by the Revenue challenging a
common order passed by the Income Tax Appellate Tribunal (ITAT) dated
30.09.2020 concerning multiple assessment years.The central issue arose from t...
PR Commissioner of Income Tax, Central-3 vs Shyam Sunder Jindal (Delhi High Court, 2023) – Notional Interest Addition Deleted u/s 254(2) & Search Assessment Principle
Facts of the
Case
The assessee was alleged to have maintained a foreign bank
account with HSBC, Geneva.
The Tribunal, in earlier proceedings, remanded the issue of
existence of the bank account to the A...
Commissioner of Income Tax (International Taxation)-1, New Delhi vs BBC World Distribution Ltd (Delhi High Court) – Distribution Revenue Not Taxable as Royalty | AY 2008-09
Facts of the
Case
The respondent/assessee, BBC World Distribution Ltd, was
granted non-exclusive global distribution rights by BBC World News
Ltd.
The assessee transferred distribution rights to BBC Wor...
PR Commissioner of Income Tax, Central-3 vs Shyam Sunder Jindal (Delhi High Court) – Section 254(2) | Notional Interest Addition on HSBC Foreign Account | No Incriminating Material Found
Facts of the
CaseThe Revenue filed appeals challenging a common
order passed by the Income Tax Appellate Tribunal (ITAT) under Section 254(2)
of the Income-tax Act for Assessment Years 2008–09 to 2011–12.The case ...