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Commissioner of Income Tax vs. Akums Drugs & Pharmaceuticals Ltd. – Deductibility of Commission Paid to Agents for Government Institutional Business under Section 37(1) of the Income-tax Act, 1961
Facts of the Case
The
assessee was engaged in manufacturing pharmaceutical formulations and
supplying medicines to Government institutions.
Commission
payments were made to various agents who assist...
Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009) | Applicability of TDS under Section 195 on Software Payments for Ticket Reservation Systems to Foreign Entities (M/s. Amadeus Marketing & M/s. Galileo International): Royalty vs. Business Income under DTAA
Facts of the Case
The
respondent/assessee, Sahara Airlines Ltd., entered into operational
agreements with two foreign entities: M/s. Amadeus Marketing (a Spanish
company) and M/s. Galileo Internationa...
Commissioner of Income Tax, Delhi vs Raghav Bahl (Delhi High Court) – No Substantial Question of Law Arises in Revenue Appeal | ITA Nos. 16/2010 & 1188/2009
Facts of the Case
The Income Tax Appellate Tribunal passed a common order dated
08.08.2008 in ITA Nos. 3555-3557/Del/2003 relating to Assessment Years
2000-01, 2001-02 and 2002-03.
The Revenue challenged...
· Commissioner of Income Tax-IV vs. Infogain India BPO Pvt. Ltd. – Settlement of Contractual Lease Liability Held Deductible Under Section 37(1) of the Income Tax Act, 1961 on Grounds of Commercial Expediency.
Facts
of the Case·
The
Assessee (Infogain India BPO Pvt. Ltd.) incurred certain settlement expenses
during the Assessment Year 2004-05.· ...
Commissioner of Income Tax vs. Akums Drugs & Pharmaceuticals Ltd. – Allowability of Commission Paid to Agents for Government Institutional Sales under Section 37(1) of the Income-tax Act
Facts of the Case
The
assessee was engaged in manufacturing pharmaceutical formulations and
supplying medicines to Government institutions.
Commission
was paid to various agents who assisted t...
Commissioner of Income Tax vs. Sahara Airlines Ltd.: High Court Rules on TDS Liability Under Section 195 for Ticket Reservation Software Payments to Foreign Companies (Amadeus & Galileo) Under DTAA
Facts of the CaseThe respondent-assessee, M/s. Sahara Airlines Ltd., entered
into operational agreements with two foreign business entities: M/s. Amadeus
Marketing (a Spanish company) and M/s. Galileo International (an...
M/s. Punjab Stainless Steel Industries vs. Commissioner of Income Tax-VII & Anr.: Delhi High Court Upholds Interest Disallowance Under Section 36(1)(iii) for Interest-Free Advances to Sister Concern in Absence of Commercial Expediency
Facts
of the Case·
Assessee
Profile & Financial Disallowance: The appellant/assessee, M/s. Punjab Stainless
Steel Industries, filed an appeal against the disallowa...
Commissioner of Income Tax vs Assessee – Foreign Tax Credit and Refund under Article 24 of the India–UK Double Taxation Avoidance Agreement (DTAA) and Section 154 of the Income-tax Act | Delhi High Court
FACTS OF THE CASE
The
appeal arose from an order of the Income Tax Appellate Tribunal concerning
entitlement to relief under the India–UK DTAA.
The
appellant relied upon Article 24 of the Do...
Commissioner of Income Tax vs. Sahara Airlines Ltd. (2009) | Applicability of TDS Under Section 195 on Software Payments for Ticket Reservation Systems to Foreign Companies (M/s. Amadeus Marketing & M/s. Galileo International): Royalty vs. Business Income Under DTAA
Facts of the Case
The
Respondent/Assessee, Sahara Airlines Ltd., entered into commercial
arrangements with two foreign companies: M/s. Amadeus Marketing (a Spanish
company) and M/s. Galileo Internatio...
S.M. Wahi vs. Director of Income Tax & Anr. (2010:DHC:2727-DB) | Section 48 of the Income Tax Act, 1961 – Delhi High Court Holds Entire Indexed Cost of Acquisition Must Be Allowed Against Capital Gains Received Under Settlement.
Facts
of the Case·
Property
Purchase and Financing:
The appellant, a Non-Resident Indian and Swiss National, financed the entire
purchase of a residential property at...