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Sony Ericsson Mobile Communications India Pvt. Ltd. vs. Commissioner of Income Tax-III ITA 613/2014 and ITA 82/2015
Facts of the Case:The
case involves two cross appeals — one filed by the assessee (Sony Ericsson
Mobile Communications India Pvt. Ltd.) and the other by the revenue
(Commissioner of Income Tax-III). These appeals co...
Canon India Pvt. Ltd. vs Deputy Commissioner of Income Tax (Delhi High Court) – Transfer Pricing Adjustment on AMP/Distributor Expenses under Section 92CA of the Income Tax Act Case Title (SEO Friendly / Google Optimized) Canon India Pvt. Ltd. vs Deputy Commissioner of Income Tax – Delhi High Court on Transfer Pricing Adjustment for Distributor Expenses | Section 92CA Income Tax Act
Facts of the Case
Canon
India Private Limited, engaged in distribution business, incurred
distributor-related expenses in the course of its operations.
The
Transfer Pricing Officer (TPO) and revenue...
Commissioner of Income Tax vs. Marubeni India Pvt. Ltd. Delhi High Court | ITA No. 94/2015 | Judgment dated 23 April 2015Transfer Pricing – TNMM vs Profit Split Method (PSM) – Agency and Marketing Support Services – Determination of Arm’s Length Price (ALP)
Facts of the CaseMarubeni
India Pvt. Ltd., a wholly owned subsidiary of Marubeni Corporation, was engaged
in providing agency and marketing support services to its group entities and
also independently engaged in trad...
Commissioner of Income Tax-VI vs. Woco Motherson Elastomer Ltd.: Delhi High Court Rejects Revenue’s 'Standard Excuses' for 526-Day Re-Filing Delay
Facts of
the Case
Initial
Actions by Revenue: The Commissioner of Income Tax-VI
preferred statutory tax appeals before the High Court of Delhi against the
assessee, Woco Motherson Elastomer Ltd...
CIT v. Rathi Graphics Technologies Ltd.: Allotment of Shares Towards Interest Outstandings is "Actual Payment" under Section 43B
Facts of the Case
Assessee
Status & BIFR Scheme: The Respondent/Assessee
(Rathi Graphics Technologies Ltd.) was under a rehabilitation scheme
sanctioned by the Board for Industrial and Financial R...
Nartel Networks India International Inc. vs Deputy Director of Income Tax, Circle 2(1), New Delhi – Delhi High Court Grants Continuation of Stay Beyond 365 Days Till Disposal of Appeal | Article 226 | Income Tax Stay Extension Case Law
Facts of the
CaseThe Petitioner had filed an appeal before the
Income Tax Appellate Tribunal (ITAT) against the assessment order dated
07.01.2014. During the pendency of the appeal, the Tribunal granted an
unconditio...
Commissioner of Income Tax-V vs. Rathi Graphics Technologies Ltd.: Extinguishment of Interest Liability via Debt-to-Equity Swap Qualifies as "Actual Payment" Under Section 43B
Facts of the Case
Rehabilitation
Scheme: The Respondent/Assessee was a company under
a rehabilitation scheme sanctioned by the Board for Industrial and
Financial Reconstruction (BIFR) on November 1, 2...
COMMISSIONER OF INCOME TAX-II vs. M/S DELHI TRANSCO LTD. Whether Wheeling Charges Paid for Electricity Transmission Constitute "Fees for Technical Services" Under Section 194J vs. Work Contract Under Section 194C of the Income Tax Act, 1961 — Delhi High Court ruling in ITA 384/2012.
Facts of the Case
The
Agreement: The Respondent, M/s Delhi Transco Ltd.
(DTL), entered into a Bulk Power Transmission Agreement (BPTA) with the
Power Grid Corporation India Ltd. (PGCIL) to receive ene...
Canon India Private Limited vs Deputy Commissioner of Income Tax Circle-5(2), New Delhi | Delhi High Court on Extension of Stay Beyond 365 Days in Tax Appeal
Facts of the
CaseThe petitioner, Canon India Private Limited, had
filed an appeal before the Income Tax Appellate Tribunal (ITAT) against the
assessment order passed by the Income Tax Department for Assessment Y...
Commissioner of Income Tax-5 vs JCDecaux Advertising India Pvt. Ltd. – Allowability of Business Expenditure after Setting Up of Business under Sections 3 and 4 of the Income-tax Act, 1961 | Delhi High Court
Facts of the CaseThe
assessee, JCDecaux Advertising India Pvt. Ltd., was incorporated in
April 2005 for carrying on the business of out-of-home advertising, including
street furniture advertising, billboards, and tran...