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Commissioner of Income Tax (International Taxation-1) vs DXC Technology Services Singapore Pte. Ltd. (Delhi High Court) – Software Payments Not Royalty under Article 12 of India-Singapore DTAA [ITA 802/2023
Facts of the
CaseThe case pertains to taxation of income received by
the assessee, a Singapore-based entity, from the sale/supply of off-the-shelf
software to various customers in India. During scrutiny assessment, th...
Commissioner of Income Tax (International Taxation)-1 vs A B Sciex Pte. Ltd. (Delhi High Court) – Permanent Establishment & Arm’s Length Pricing Remand Case
Facts of the CaseThe appeals were filed by the Revenue (Commissioner of
Income Tax – International Taxation) challenging orders passed by the Income
Tax Appellate Tribunal for Assessment Years 2017–18, 2018–19, a...
Principal Commissioner of Income Tax vs National Fertilizers Ltd (Delhi High Court) – Jurisdiction, Taxability & Substantial Question of Law under Section 260A
Facts of the
CaseThe appeal was filed by the Revenue before the
Delhi High Court under Section 260A of the Income Tax Act, 1961 against the
order of the Income Tax Appellate Tribunal (ITAT). The dispute arose from
as...
Commissioner of Income Tax (International Taxation)-3 vs Zaheer Mauritius | Delhi High Court | Section 2(28A) & DTAA Article 11 vs Article 13 | Taxability of CCD Transfer Gains
Facts of the
CaseThe case pertains to Assessment Years 2013–14 and
2014–15, where the Revenue challenged the orders of the Income Tax Appellate
Tribunal (ITAT), which ruled in favor of the assessee, Zaheer Mauriti...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 (Section 260A | Permanent Establishment | DTAA India-UAE | Royalty vs Business Income)
Facts of the
CaseThe appellant, Hyatt International Southwest Asia
Ltd., is a company incorporated in the UAE and a tax resident under the
India-UAE Double Taxation Avoidance Agreement (DTAA). The appellant entered in...
CIT (International Taxation) vs Saif Partner India IV Ltd – Delhi High Court | Section 263 Revision Invalid Without Twin Conditions (ITA 809/2023)
Facts of the
CaseThe case pertains to an appeal filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), which had
set aside the revisionary order passed under Section 263.The Assessing ...
Hyatt International Southwest Asia Ltd. vs. Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 | Permanent Establishment & Profit Attribution Despite Global Losses
Facts of the
CaseHyatt International Southwest Asia Ltd., a
UAE-based company, was engaged in providing hotel management and strategic
advisory services to hotels in India. The Indian tax authorities held that the
co...
PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 vs SANJAY SINGHAL (Delhi High Court) – Reopening Beyond Limitation u/s 149 Not Permissible u/s 150 | ITA 807/2023
Facts of the CaseThe case
pertains to addition made by the Assessing Officer (AO) amounting to ₹11.35
crores on account of alleged undisclosed income arising from trading activities
in commodities such as pulses and...
Commissioner of Income Tax (Central-1) vs RRPR Holding Pvt. Ltd. – Section 14A Disallowance Cannot Exceed Exempt Income | Delhi High Court
Facts of the
CaseThe appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT) for Assessment Year 2009–10.The Assessing Officer invoked Section 14A read with
Rule 8D and made...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of Permanent Establishment Profits Despite Global Losses under Article 7 DTAA & Income Tax Act
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, was engaged in providing hotel management and
oversight services in India. It entered into agreements with Indian hotel
own...