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Rolls Royce PLC vs Director of Income Tax (International Taxation) | Delhi High Court | Permanent Establishment in India under Article 5 of India–UK DTAA and Attribution of Profits to PE
Facts of the
CaseRolls Royce PLC, a company incorporated in England
and Wales and a tax resident of the United Kingdom, supplied aircraft and
equipment to Indian customers including the Indian Navy, Indian Air Force a...
Rolls Royce Singapore Pte. Ltd. vs Assistant Director of Income Tax – Dependent Agent Permanent Establishment (PE), Arm’s Length Principle and Taxability of Business Profits under India–Singapore DTAA | Delhi High Court
Facts of the CaseRolls Royce Singapore Pte. Ltd., a company
incorporated in Singapore, was engaged in supplying spare parts, repair
services, maintenance services, and technical support relating to oil-field
equipment...
Commissioner of Income Tax vs. Vasisth Chay Vyapar Ltd. (2011) – Inter-Corporate Deposits (ICDs) Not Taxable as Interest on Loans or Advances under Sections 2(7) & 5 of the Interest Tax Act, 1974
Facts of the CaseThe assessee company, Vasisth Chay Vyapar Ltd.,
placed Inter-Corporate Deposits (ICDs) amounting to ₹22 crores with Shaw
Wallace & Company Ltd. (SWC) after passing a Board Resolution authorizing
...
Rollatainers Ltd. vs Commissioner of Income Tax (Delhi High Court) – Taxability of Waiver of Working Capital Loan under Sections 41(1), 28(iv) and 2(24) of the Income-tax Act, 1961
Facts of the CaseThe assessee, Rollatainers Ltd., was engaged in the
business of manufacturing lined and flexible cartons, packing materials,
automatic packing machines, weighing machines, trading of machinery and spar...
Rolls Royce Plc v. Director of Income Tax (International Taxation) [2011] Delhi High Court – Permanent Establishment (PE) in India, Attribution of Profits under Indo-UK DTAA, Business Connection under Section 9(1)(i), and Taxability of Foreign Enterprises
Facts of the Case
Rolls Royce Plc was incorporated in the United
Kingdom and was a non-resident for Indian tax purposes.
The company supplied aircraft engines, parts,
equipment, and related products to In...
Commissioner of Income Tax v. Assessee Company – Allowability of Insurance Premium Paid for Customers as Business Expenditure under Section 37(1) of the Income Tax Act | Delhi High Court
Facts of the Case
The assessee was engaged in the manufacture and sale of urea.
It introduced an insurance scheme under which every purchaser of a
bag of urea was insured for ₹4,000.
The assessee paid insur...
Commissioner of Income Tax vs. Smt. Anita Gupta – Addition Towards Jewellery and Cost of Construction Cannot Be Sustained Solely on Income Tax Inspectors’ Estimate | Delhi High Court
Facts of the CaseA search and seizure operation was conducted at the
residential premises of the assessee and her husband on 19 April 2006. Search
proceedings were also carried out in the assessee’s bank lockers. Dur...
Commissioner of Income Tax vs. [Assessee] – Lease Premium Paid to NOIDA Authority on 90-Year Lease Held as Capital Expenditure | Section 269UA, Income Tax Act | Delhi High Court
Facts of the Case
The assessee acquired land from the NOIDA Authority on leasehold
rights for a period of 90 years.
A lease premium of ₹2,75,045 was paid by the assessee.
The Assessing Officer held that, in...
Future Use of Agricultural Land by Purchaser Cannot Determine Taxability on Date of Sale: ITAT Ahmedabad Deletes LTCG Addition and Holds Section 50C Inapplicable | Jignesh Harshadbhai Patel v. ITO [2026]
Future Intended Use of Agricultural Land by Purchaser Cannot Determine Nature of Land on Date of Transfer; ITAT Ahmedabad Deletes LTCG Addition and Holds Section 50C InapplicableFacts of the CaseThe assessee had sold cer...
Commissioner of Income Tax v. Gold Leaf Capital Corporation Ltd. | Section 68 Income Tax Act | Unexplained Share Application Money | Repeated Remand by ITAT Not Permissible for Filling Evidentiary Lacunae
Facts of the CaseThe assessee company received substantial amounts
as share capital and share application money from various entities during
Assessment Year 1995-96. During assessment proceedings, the Assessing Officer...