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Pr. Commissioner of Income Tax-5 vs Jaypee Powergrid Ltd. (Delhi High Court, AY 2009–10) – Interest on Fixed Deposits During Pre-Commencement Period: Capital Receipt vs Income from Other Sources
Facts of the
Case
The respondent/assessee, Jaypee Powergrid Ltd., was
incorporated as a joint venture to set up a power transmission system in
Himachal Pradesh.
The project was funded through:
Eq...
A.C. Surgipharma Private Limited vs Deputy Commissioner of Income Tax Circle 1(1) & Anr. | Delhi High Court | Section 115BAA, Section 143(1), Section 119(2)(b) Income Tax Act
Facts of the
CaseThe petitioner, A.C. Surgipharma Private Limited,
filed its income tax return for Assessment Year 2021–22, opting for
taxation at the concessional rate of 22% under Section 115BAA of the Income
Tax...
Commissioner of Income Tax (International Taxation)–3 vs Travelport Global Distribution System B.V. (Delhi High Court, ITA 718/2023 & Connected Appeals, AY 2007–08 to 2014–15) – Profit Attribution & No Substantial Question of Law
Facts of the
CaseThe present appeals were filed by the Revenue
challenging a common order dated 13.10.2021 passed by the Income Tax Appellate
Tribunal concerning multiple assessment years (AY 2007–08 to AY 2014–15...
Commissioner of Income Tax (International Taxation)-2 vs Kony Inc. | Delhi High Court | ITA 669/2023 | AY 2015–16 | Software Licence Not Royalty & AMC Not FTS under Section 9(1)(vi) & 9(1)(vii) r/w India–USA DTAA
Facts of the CaseThe present appeal was filed by the Revenue before the Delhi High Court
against the order of the Income Tax Appellate Tribunal dated 11.01.2023 for
Assessment Year 2015–16. The respondent-assessee, K...
Commissioner of Income Tax (International Taxation)-1 vs Augustus Capital Pte. Ltd. | Delhi High Court | Section 9(1)(i) – Retrospective Applicability of Explanations 6 & 7
Facts of the
Case
The assessee, Augustus Capital Pte. Ltd., a Singapore-based
company, invested in shares of Accelyst Pte. Ltd. (Singapore).
Total investment: ₹4.91 crore.
The assessee sold its shares to...
Commissioner of Income Tax (International Taxation)-1 vs Augustus Capital Pte. Ltd. | Delhi High Court | Section 9(1)(i) – Retrospective Applicability of Explanations 6 & 7
Facts of the
Case
The assessee, Augustus Capital Pte. Ltd., a Singapore-based
company, invested in shares of Accelyst Pte. Ltd. (Singapore).
Total investment: ₹4.91 crore.
The assessee sold its shares to...
Principal Commissioner of Income Tax, Delhi-7 vs M/s Timex Group India Ltd. (Delhi High Court) – AMP Expenses & Bright Line Test under Transfer Pricing
Facts of the
CaseThe present appeal was filed by the Revenue against
the order dated 27.03.2023 passed by the Income Tax Appellate Tribunal
concerning Assessment Year 2010-11.The central issue arose from an adjustment...
Commissioner of Income Tax (International Taxation)-3 vs Travelport Global Distribution System B.V. (Delhi High Court) – No Substantial Question of Law on Profit Attribution to Indian Operations
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order dated 13.10.2021 passed by the
Income Tax Appellate Tribunal (ITAT).The dispute pertained to the attribution o...
Chief Commissioner of Income Tax (Central-1) vs Vishnu Apartments Pvt. Ltd. – Delhi High Court | Section 143(3) | Deletion of Addition on Alleged Sham Collaboration Agreement
Facts of the
CaseThe present appeal pertains to Assessment Year
2010–11, wherein the Revenue challenged the order dated 30.01.2020 passed
by the Income Tax Appellate Tribunal.The core issue arises from a collaborati...
GoDaddy.com LLC vs Assistant Commissioner of Income Tax | Delhi High Court | Domain Registration Fees Not Royalty u/s 9(1)(vi)
Facts of the
Case
The assessee, GoDaddy.com LLC, is a US-based company engaged in
domain registration, web hosting, and web design services.
The Assessing Officer treated income received from domain name
...