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Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Whether Consideration for Supply of Customized Software Constitutes Royalty under Article 12 of Indo-US DTAA read with Section 9(1)(vi) and Liability of Interest under Section 234B of the Income Tax Act
Facts of the CaseThe Revenue preferred appeals under Section 260A of the
Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal
(ITAT) for multiple assessment years concerning the taxability of pay...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (Delhi High Court) – Condonation of 960 Days’ Delay in Re-filing Income Tax Appeals Rejected under Section 260A of the Income Tax Act
Facts of the
CaseThe appellant, Eastern India Powertech Ltd.,
had originally instituted multiple income tax appeals in April 2013. The
appeals were returned with office objections for rectification within time.
...
Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Delhi High Court on Taxability of Customized Software Payments as Royalty under Section 9(1)(vi), Section 234B & Article 12 of India-USA DTAA
Facts of the CaseThe Revenue challenged the order passed by the Income Tax
Appellate Tribunal (ITAT) for multiple assessment years wherein the Tribunal
held that the consideration received by Aspect Software Inc. for s...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (Delhi High Court) – Condonation of 960 Days Delay in Re-filing Income Tax Appeals Rejected
Facts of the
CaseThe appellant, Eastern India Powertech Ltd., had
originally filed multiple income tax appeals in April 2013 under Section 260A
of the Income Tax Act. The appeals were returned with procedural objectio...
Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Delhi High Court on Taxability of Customized Software Payments as Royalty under Section 9(1)(vi), Article 12 of Indo-US DTAA & Interest under Section 234B
Facts of the CaseThe Revenue filed multiple appeals under Section 260A of the
Income Tax Act against the order of the Income Tax Appellate Tribunal (ITAT)
concerning various assessment years. The dispute pertaine...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (CIT) — Delay in Re-filing Income Tax Appeals Not Condoned | Delhi High Court | Section 260A of the Income-tax Act, 1961
Facts of the
Case
The appellant, Eastern India Powertech Ltd., had filed
several Income Tax Appeals before the Delhi High Court.
The appeals were originally instituted in April 2013 within
the prescribe...
Commissioner of Income Tax (International Taxation)-1 vs Aspect Software Inc. | Whether Consideration for Supply of Customized Software Constitutes Royalty under Section 9(1)(vi) and Article 12 of Indo-US DTAA | Delhi High Court
Facts of the CaseThe Revenue filed appeals under Section 260A challenging the
order of the Income Tax Appellate Tribunal (ITAT) for multiple assessment
years. The dispute arose regarding payments received by Aspect Sof...
Commissioner of Income Tax (International Taxation)-3 vs Travelport L.P. USA | Delhi High Court on Remand of International Tax Appeals for AY 2009–10 & 2010–11 under Income Tax Act
Facts of the CaseThe Revenue preferred appeals before the Delhi High Court
challenging the ITAT’s order dated 19 September 2016 in respect of Assessment
Years 2009–10 and 2010–11.It was brought to the Court’s a...
Commissioner of Income Tax (International Taxation)-3 vs Travelport L.P. USA | Delhi High Court on Remand of International Tax Appeals under Income Tax Act (AY 2009-10 & 2010-11)
Facts of the CaseThe Revenue preferred appeals before the Delhi High Court
against the orders of the Income Tax Appellate Tribunal dated 19 September 2016
concerning Assessment Years 2009-10 and 2010-11. The respondent...
Eastern India Powertech Ltd. vs Commissioner of Income Tax (Delhi High Court) – Condonation of 960 Days Delay in Re-filing Income Tax Appeals Rejected
Facts of the
CaseThe appellant, Eastern India Powertech Ltd., had
originally filed multiple income tax appeals in April 2013 under Section 260A
of the Income Tax Act. The appeals were returned with procedural objectio...