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Director of Income Tax (International Taxation) vs. M/s GE Packaged Power Inc. (and Connected Matters) – High Court of Delhi Section 234B
Facts of the Case
Corporate
Structure and Business Operations: The respondents are eight
distinct, interconnected foreign corporate entities operating within the
overarching organizational framework o...
Director of Income Tax (International Taxation) vs. GE Japan Ltd.: Immunity of Non-Resident Assessees from Section 234B Interest Penalties Amidst TDS Deductor Defaults
Facts of the Case
The
batch of appeals was preferred by the Revenue (Director of Income Tax,
International Taxation) under Section 260A of the Income Tax Act, 1961,
challenging a common order passed b...
Director of Income Tax (International Taxation) v. M/S GE Packaged Power Inc. & Ors. (with connected matters) Section 260A
Facts of the CaseThe Revenue, through the Director of Income Tax (International
Taxation), filed a massive batch of forty-one interconnected income tax appeals
(led by ITA 353/2014 and running through ITA 391/2014 and ...
Judicial Review of International Tax Assessments: Director of Income Tax v. GE Group Entities (2015:DHC:266-DB)
Facts of the CaseThe matter concerns a series of 38 linked Income Tax Appeals
(ITA 353/2014 to ITA 391/2014) filed by the Director of Income Tax
(International Taxation). The appeals were brought before the High Court ...
Legal Analysis: Taxability of Cross-Border Payments under DTAA – Director of Income Tax (International Taxation) v. M/S GE Packaged Power Inc. & Ors.
Facts of the CaseThe case comprises a series of connected Income Tax Appeals,
specifically ITA 353/2014 through ITA 391/2014, and ITA 402/2014. The
Appellant, the Director of Income Tax (International Taxation), initia...
Judicial Interpretation of 'Fees for Technical Services' and Permanent Establishment: Director of Income Tax (International Taxation) vs. GE Group Entities (2015)
Facts of the Case: The
litigation arose from the Revenue’s challenge to orders passed by the Income
Tax Appellate Tribunal (ITAT) in favor of various GE group companies. These
companies, operating internationally, e...
Director of Income Tax (International Taxation) v. M/s GE Packaged Power Inc. & Ors.: Adjudicating the Scope of Taxability of International Transactions under Section 9 of the Income Tax Act, 1961
Facts of the Case
The
appellant, the Director of Income Tax (International Taxation), challenged
the appellate orders passed in favor of several GE entities, including M/s
GE Packaged Power Inc., GE J...
Judicial Review of International Tax Assessments: Director of Income Tax v. M/S GE Packaged Power Inc. & Ors. Section 260A
Facts of the CaseThe High Court of Delhi presided over a large batch of
connected tax appeals involving the Director of Income Tax (International
Taxation) as the Appellant and several multinational entities under the ...
Director of Income Tax (International Taxation) vs. GE Japan Ltd. – Whether Payments for Maintenance, Repair and Overhaul Services Constitute “Fees for Technical Services” under Sections 9(1)(vii), 44D & Article 12 of DTAA | Delhi High Court
Facts of the CaseThe appeals were filed by the Director of Income Tax
(International Taxation) against various General Electric group entities,
including GE Japan Ltd., concerning the taxability of receipts arising fro...
Director of Income Tax (International Taxation) vs. GE Packaged Power Inc. & Connected Matters | Delhi High Court | Sections 9(1)(vii), 44BB & 115A of the Income Tax Act | Taxability of Offshore Service and Technical Service Income
Facts of the CaseSeveral foreign companies belonging to the GE Group, including
GE Packaged Power Inc., GE Jenbacher GmbH & Co. OHG, GE Nuovo Pignone
S.P.A., GE Engine Services Distribution LLC, GE Energy Parts Inc...