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Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. (Delhi High Court) – Section 260A Income Tax Appeal on Tribunal Order & Corporate Insolvency Impact
Facts of the Case
The Revenue preferred an appeal before the Delhi High Court against
the order passed by the ITAT.
The respondent/assessee, part of the Amrapali Group, was undergoing
Corporate Ins...
Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. | Delhi High Court | ITA 329/2022 | Income Tax Appeal on CIRP & Maintainability of Proceedings
Facts of the
Case
The Revenue filed an appeal under Section 260A of the Income Tax
Act before the Delhi High Court against the order of the Income Tax
Appellate Tribunal.
The respondent company belonged...
Pr. Commissioner of Income Tax–1 vs Amrapali Silicon City Pvt. Ltd. | Delhi High Court | Section 260A read with Sections 40(a)(i) & 195 of Income Tax Act – Disallowance on Payments to Non-Residents & DTAA Override
Facts of the
CaseThe Revenue filed an appeal before the Delhi High
Court challenging the order of the Income Tax Appellate Tribunal (ITAT), which
had deleted disallowances made under Section 40(a)(i) of the Income Tax...
PR. COMMISSIONER OF INCOME TAX–1 vs AMRAPALI SILICON CITY PVT. LTD. (Delhi High Court) – Section 260A Appeal | Liberty to Revive Appeal in Insolvency Context
Facts of the
CaseThe appeal was filed by the Revenue under Section
260A of the Income-tax Act challenging the order passed by the Income Tax
Appellate Tribunal (ITAT) in favour of the assessee, Amrapali Silicon ...
PR. COMMISSIONER OF INCOME TAX-1 vs AMRAPALI SILICON CITY PVT. LTD. (Delhi High Court) – Section 260A | Income Tax Appeal on Tribunal Order & Insolvency Proceedings
Facts of the
Case
The Revenue filed multiple appeals (including ITA 329/2022) against
orders passed by the ITAT concerning different assessment years.
The respondent company, part of the Amrapali Group, was
...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – ITA No. 216/2020 [Section 260A | DTAA | Permanent Establishment | Royalty vs Business Income]
Facts of the
CaseThe assessee, a UAE-based company, provided
strategic and advisory services to hotels in India under Strategic Oversight
Services Agreements (SOSA). It claimed that such services were rendered from
o...
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...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Section 9, 143(3), 144C, 260A | Permanent Establishment & DTAA Taxability
Facts of the
CaseThe assessee, Hyatt International Southwest Asia
Ltd., a UAE-based company, entered into Strategic Oversight Services Agreements
(SOSA) with hotel entities in India for providing advisory and strategi...
Hyatt International Southwest Asia Ltd. vs Additional Director of Income Tax (Delhi High Court) – Taxability of SOSA Services, Royalty vs Business Income & Permanent Establishment under DTAA
Facts of the
case
The assessee, Hyatt International Southwest Asia Ltd., is a
UAE-based company providing strategic and advisory services to hotels
under Strategic Oversight Services Agreements (SOSA).
...
Commissioner of Income Tax (International Taxation)-2 vs. Sh. Hotchand Techchand Punjabi (Delhi High Court) – Section 250(4), Rule 46A, Sections 147, 148, 69B of Income Tax Act – Admission of Additional Evidence & Scope of CIT(A) Powers
Facts of the
CaseThe present matter pertains to Assessment Year
2012–13, wherein the Assessing Officer (AO) initiated reassessment
proceedings under Sections 147 and 148 of the Income Tax Act, 1961 based
on informa...