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Director of Income Tax, New Delhi vs. Sheraton International Inc. — High Court of Delhi Judgement on the Taxability of Composite Fees as Business Profits vs. Royalty and Fees for Included Services under the Indo-USA Double Taxation Avoidance Agreement (DTAA)
Facts of the Case
The
Assessee: Sheraton International Inc. is a
company incorporated in the USA and a non-resident under Indian tax laws,
specializing in providing global hospitality and hotel-relate...
Director of Income Tax, New Delhi vs. Sheraton International Inc.: Whether Composite Fees Received by a Non-Resident for Global Marketing, Publicity, and Centralized Reservation Services Constitute Taxable Royalty/Fees for Included Services or Exempt Business Profits under the Indo-USA DTAA in the Absence of a Permanent Establishment
Facts of the Case
The assessee, Sheraton International Inc., is a company
incorporated in the USA and qualifies as a non-resident under Indian tax
laws. It specializes in providing comprehensive hospitality...
Director of Income Tax, New Delhi vs. Sheraton International Inc.
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a non-resident company incorporated under the laws
of the USA, specializing in providing comprehensive hotel-related
...
Director of Income Tax, New Delhi vs. M/s Sheraton International Inc.: Taxability of Integrated Global Marketing, Advertisement, and Reservation Services Under India-USA DTAA—Whether Receipts Constitute Business Profits in Absence of PE or Taxable as Royalty / Fee for Included Services (FIS) Under Section 9(1) of Income Tax Act, 1961
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a company incorporated in the USA and a
non-resident under Indian tax laws. It is engaged in providing worldwide
...
Commissioner of Income Tax v. Assessee (Name Not Available in Extract) – Appeal Dismissed Due to Low Tax Effect Under CBDT Instruction No. 5/2008 [Delhi High Court]
Facts
of the CaseThe Revenue preferred appeals
before the Delhi High Court under the Income-tax Act, 1961. The matters related
to different assessment years. At the stage of admission, the Court examined
the maintain...
Director of Income Tax, New Delhi vs. M/s Sheraton International Inc.: Whether Composite Fees Received by a Non-Resident Foreign Entity for Global Hotel Marketing, Publicity, and Centralized Reservation Network Services Are Taxable as Royalties/Fees for Included Services or Exempt as Business Profits under Section 9 of the Income Tax Act, 1961 and Articles 7 & 12 of the Indo-US DTAA in the Absence of a Permanent Establishment in India
Facts of the Case
The
Assessee (Sheraton International Inc.) is a company incorporated in the
USA and qualifies as a non-resident under Indian tax laws. It provides
specialized marketing, publicity, a...
Commissioner of Income Tax vs Assessee – Delhi High Court Dismisses Revenue Appeal Due to Low Tax Effect Under CBDT Instruction No. 5/2008 | ITA No. 681/2009
Facts of the
CaseThe Revenue preferred an appeal before the Delhi
High Court under Section 260A of the Income-tax Act, 1961. The matter came up
along with several connected appeals. The Court examined the maintainabil...
Commissioner of Income Tax v. [Name of Assessee Not Available in Uploaded Order] – Delhi High Court Dismisses Revenue Appeals Due to Low Tax Effect under CBDT Instruction No. 5/2008 (ITA No. 332/2009 and Connected Matters)
Facts
of the CaseThe matter concerned a batch of
Income Tax Appeals, including ITA No. 430/2009, ITA No. 680/2009, ITA No.
681/2009, ITA No. 328/2009 and ITA No. 332/2009. The Revenue preferred the
appeals befo...
Commissioner of Income Tax, Delhi (Central)-I vs. Assessee/Petitioner – Demand Notice Cannot Be Enforced Until Appeal Effect Orders Are Passed | Delhi High Court
Facts of the
Case
The Income Tax Department issued a demand notice dated 15 January
2009.
The notice sought recovery of tax demands for Assessment Years
1989-90 to 2004-05.
The petitioner had already p...
Meena Chaudhary vs Income Tax Authorities & Others | Delhi High Court Directs Action Against Company for Failure to Deposit TDS Deducted from Rent| under section Section 148
Facts of the
CaseThe petitioner, Ms. Meena Chaudhary, had let out
the third floor of premises known as Vikas Tower, Delhi-110085, measuring
approximately 2900 sq. ft., to M/s Bitcom Services Pvt. Ltd. through its
Dir...