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Director of Income Tax (International Taxation) vs. M/s Modiluft Ltd. & Connected Matters (Royal Airways Ltd.) – Delhi High Court | DTAA Interpretation & Remand to ITAT
Facts of the Case
The
appeals were filed by the Director of Income Tax (International Taxation)
against M/s Modiluft Ltd. and M/s Royal Airways Ltd.
The
disputes arose from orders passed by the Inc...
Director of Income Tax (International Taxation) vs M/s Modiluft Ltd. & Connected Matters (Delhi High Court, 2018) – Remand to ITAT for Fresh Adjudication under DTAA
Facts of the CaseThe present batch of appeals was filed by the Director of
Income Tax against M/s Modiluft Ltd. and M/s Royal Airways Ltd.
along with several connected matters.The dispute arose from orders passed by th...
PR. COMMISSIONER OF INCOME TAX–4 vs CYAN ENTERPRISES PVT. LTD. | Delhi High Court | Section 260A Income Tax Act | Share Transfer Valuation & Capital Gains vs Business Income
Facts of the Case
The assessee, Cyan Enterprises Pvt. Ltd., held 77%
shareholding in M/s Trojan Developers Pvt. Ltd. and transferred its shares
for a declared consideration of ₹5.03 crores.
The Assessing Offic...
Principal Commissioner of Income Tax-4 vs Gyan Enterprises Pvt. Ltd. (Delhi High Court, 2018) – Section 260A | Share Valuation & Capital Gains vs Business Income
Facts of the CaseThe appeal was filed by the Revenue under Section 260A of the
Income Tax Act, 1961 challenging the deletion of an addition of ₹3.22 crores
made by the Assessing Officer (AO). The assessee, holding 77...
Commissioner of Income Tax (International Taxation)–1 vs GE Engine Service Distribution LLC & Connected Matters (2018) – Delhi High Court | Section 234B Interest on Non-Residents
Facts of the CaseThe present batch of appeals was filed by the Revenue against
multiple foreign entities of the GE Group concerning liability to pay interest
under Section 234B of the Income Tax Act, 1961.The issue aro...
Commissioner of Income Tax (International Taxation) v. GE Engine Services Group Entities – Section 234B Interest Liability on Non-Residents | Delhi High Court (2018)
Facts of the CaseThe Revenue filed multiple appeals against various GE group
entities (non-resident companies) challenging the orders of the Income Tax
Appellate Tribunal (ITAT).The central issue pertained to the levy ...
Commissioner of Income Tax (International Taxation)-1 vs GE Engine Service Distribution LLC & Ors – Section 234B Interest Not Applicable on Non-Residents Where TDS Liability Exists | Delhi High Court
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High Court
against various GE group entities (non-resident assessees), challenging the
orders of the Income Tax Appellate Tribunal (ITAT).The core is...
Commissioner of Income Tax (International Taxation)–1 vs GE Engine Service Distribution LLC & Connected Matters (Delhi High Court, 2018) – Section 234B Interest on Non-Resident Assessees
Facts of the CaseThe present batch of appeals was filed by the Revenue
(Commissioner/Principal Commissioner of Income Tax – International Taxation)
against multiple non-resident entities including GE Engine Service D...
Commissioner of Income Tax (International Taxation)-1 vs GE Engine Services & Connected Matters (Delhi High Court) – Section 234B Interest on Non-Residents
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High Court
against various GE group entities and other assessees. The central issue across
all connected matters pertained to the levy of interest un...
Commissioner of Income Tax (International Taxation) v. GE Engine Services Entities & Connected Matters (Delhi High Court, 2018) – Section 234B Interest Liability on Non-Residents
Facts of the Case
The
Respondents (GE group entities and others) are non-resident companies
engaged in providing services and business operations involving India.
The Assessing
Officer levied inter...