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Director of Income Tax (International Taxation) vs GE Engine Services Distribution LLC – Delhi High Court on Offshore Supply, Permanent Establishment & Taxability under Section 9(1)(i) read with India-USA DTAA | ITA 366/2014
Facts of the CaseThe dispute arose in relation to the taxability of income
earned by GE group foreign entities, including GE Engine Services Distribution
LLC, from offshore supply and related activities connected with ...
Director of Income Tax (International Taxation) vs. GE Group Entities | Delhi High Court | Sections 9(1)(vii), 44BB & DTAA | Taxability of Offshore Services and Equipment Supply
Facts of the CaseThe appeals were filed by the Revenue against multiple GE group
entities including GE Packaged Power Inc., GE Jenbacher GmbH & Co. OHG, GE
Nuovo Pignone S.P.A., GE Engine Services Distributio...
Commissioner of Income Tax (Central)–I & Connected Appeals vs Mohan Meakins Ltd. & Others – Delhi High Court on Block Assessment and Addition under Income Tax Act
Facts of the CaseThe Revenue preferred several appeals against different
assessees including Mohan Meakins Limited, National Industries Corporation
Limited, Superior Industries Limited, DCM Shriram Industries Lim...
Legal Analysis: Tax Deduction Obligations on Payments to Non-Residents under Section 195(1) of the Income Tax Act
Facts of the CaseThe appellant, the Director of Income Tax (International
Taxation), initiated these appeals to challenge the orders previously passed by
the lower tax authorities regarding the respondents. The respond...
Director of Income Tax vs. GE Packaged Power Inc.: Judicial Interpretation of Section 195 TDS Obligations
Facts of the CaseThe Appellant, representing the Income Tax Department,
challenged earlier appellate orders that had ruled in favor of various
GE-affiliated entities, including GE Packaged Power Inc., GE Jenbacher GMBH...
Director of Income Tax, International Taxation v. M/s GE Packaged Power Inc. (and Connected Matters): Core Determinations on Permanent Establishment and Deemed Income Accrual Under Section 9(1) of the Income-tax Act, 1961
Facts of the CaseThe Income Tax Department, via the Director of Income Tax,
International Taxation, preferred a massive, consolidated batch of income tax
appeals before the Division Bench of the Hon’ble High Court of...
Commissioner of Income Tax (Central) v. Mohan Meakins Ltd., Saraya Industries Ltd., Superior Industries Ltd. & Others | Delhi High Court | ITA Nos. 430–433/2013 & Connected Appeals
Facts of the Case
Multiple
Income Tax Appeals were filed before the Delhi High Court by the
Commissioner of Income Tax against different assessees.
The
appeals involved similar legal and factual qu...
Director of Income Tax vs. M/s GE Packaged Power Inc. | Section 260A of the Income-tax Act, 1961
Facts of the CaseThe Revenue (Director of Income Tax, International Taxation)
filed a batch of interconnected cross-appeals directed against various foreign
entities belonging to the General Electric (GE) group. ...
Commissioner of Income Tax v. Saraya Industries Ltd. | Delhi High Court | Section 260A Income Tax Act | Deduction of Business Expenditure and Revenue Appeal Principles
Facts of the Case
The
Revenue preferred an appeal before the Delhi High Court challenging the
order passed in favour of the assessee.
The
appeal formed part of a group of connected income tax appea...
Income Tax Appeals on Permanent Establishment under Section 9(1)(i): Director of Income Tax v. M/S GE Packaged Power Inc.
Facts of the CaseThe Revenue (Director of Income Tax, International Taxation)
preferred a massive multi-case batch of income tax appeals against various
foreign entities operating under the corporate umbrella of the Ge...