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PR. Commissioner of Income Tax, Delhi-2 vs Blue Scope Steel India Pvt. Ltd. (2019) – Delhi High Court | Transfer Pricing | Section 92CA & 260A | Expat Salary Reimbursement Not NIL
Facts of the CaseThe assessee, a subsidiary of an Australian entity, was
engaged in rendering business support services. Due to its inability to fully
perform assigned functions, a joint venture (JV) was created ...
Pr. Commissioner of Income Tax-3 vs DU Securities Pvt. Ltd. (Delhi High Court) – Commission on Accommodation Entries Restricted to 0.5% – No Substantial Question of Law – Sections 260A & Income Tax Principles
Facts of the CaseThe present matter pertains to multiple appeals filed by the
Revenue against a common order passed by the Income Tax Appellate Tribunal
(ITAT) concerning Assessment Years 2005–06, 2006–07, 2007–0...
PR. Commissioner of Income Tax-3 vs DU Securities Pvt. Ltd. | Delhi High Court | Commission on Accommodation Entries @0.5% Upheld | No Substantial Question of Law
Facts of the Case
The
Revenue filed multiple appeals against a common ITAT order covering
several assessment years (2005–06, 2006–07, 2007–08, and 2009–10).
The
Assessing Officer (AO) had d...
Jay Polychem India Ltd. & Anr. vs Assistant Commissioner of Income Tax (2018) – Prosecution for Delay in Filing ITR under Sections 276CC & 142(1) Upheld by Delhi High Court
Facts of the
CaseThe respondent (Income Tax Department) filed a
criminal complaint against the petitioners for failure to file Income Tax
Return (ITR) within the prescribed time for Assessment Year 2012–13. The
Met...
Pr. Commissioner of Income Tax-3 vs DU Securities Pvt. Ltd. (2019:DHC:7418-DB) – Determination of Commission Rate on Accommodation Entries at 0.5% | Delhi High Court
Facts of the CaseThe Revenue filed multiple appeals before the Delhi High
Court challenging a common order of the Income Tax Appellate Tribunal (ITAT).
The dispute pertained to Assessment Years 2005-06, 2006-07, 2007-0...
Commissioner of Income Tax (International Taxation) vs Nortel Network Singapore Pte Ltd (2018) – No Permanent Establishment & Software Payment Not Royalty under India-Singapore DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A challenging
the findings in favour of Nortel Network Singapore Pte Ltd regarding taxability
issues. The primary contention was that the respondent had a Pe...
PR. Commissioner of Income Tax Delhi-2 vs Blue Scope Steel India Pvt. Ltd. (2019) – Delhi High Court | Transfer Pricing | Section 92CA & 260A | Salary Reimbursement to AE
Facts of the CaseThe present appeals were filed by the Revenue
under Section 260A of the Income Tax Act, 1961 before the Delhi High Court for
Assessment Years 2007-08, 2008-09, and 2009-10. The respondent-assesse...
Pr. Commissioner of Income Tax-3 vs DU Securities Pvt. Ltd. (Delhi High Court) – Accommodation Entries Commission Rate Reduced to 0.5% | No Substantial Question of Law
Facts of the Case
The
Revenue filed appeals against a common order passed by the ITAT concerning
multiple assessment years (2005–06, 2006–07, 2007–08, and 2009–10).
The
Assessing Officer ha...
IHHR Hospitality Pvt. Ltd. vs Additional Commissioner of Income Tax (2019) – Reassessment u/s 147/148 Invalid Without Fresh Tangible Material | Delhi High Court
Facts of the CaseAs per the judgment :
The
petitioner, engaged in the hospitality business, filed its return
declaring losses of ₹76.94 crores for AY 2011–12.
The
case was selected for scrutiny...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd | Delhi High Court | Section 260A | Permanent Establishment & Royalty under DTAA
Facts of the
CaseThe Revenue filed appeals under Section 260A of the
Income Tax Act, 1961 against Nortel Networks Singapore Pte Ltd. The dispute
pertained to:
Whether the assessee constituted a Permanent Establishme...