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Discovery Networks Asia Pacific Pte Ltd vs ACIT – ITAT Delhi: Taxation of Advertisement & Distribution Revenue under India–Singapore DTAA; MAP Resolution Applied for PE Profit Attribution (Sections 9(1)(vi), 143(3), 144C, 271(1)(c))
Facts of the
CaseDiscovery Networks Asia Pacific Pte Ltd (DNAP), a
tax resident of Singapore under Article 4 of the India–Singapore Double
Taxation Avoidance Agreement (DTAA), is engaged in broadcasting television
...
ITAT Delhi: Additional Claim Can Be Raised Before Tribunal Even If Not Claimed in Return – Max Life Insurance Co. Ltd vs DCIT | Section 254, Section 10(15)(iv)(h), Section 44
Facts of the
CaseThe assessee, M/s Max Life Insurance Co. Ltd, is engaged in the business of life
insurance. For the relevant assessment years 2015-16 and 2016-17, the assessee filed its return of income
declaring tax...
ITAT Delhi: Exemption u/s 10(15)(iv)(h) Can Be Raised as Additional Ground Before ITAT Even If Not Claimed Earlier – Max Life Insurance Co. Ltd vs DCIT (ITA Nos. 2574/DEL/2019, 9425/DEL/2019, 9475/DEL/2019)
Facts of the CaseThe assessee, M/s Max Life Insurance Co. Ltd, is engaged in the business of
providing life insurance services.For AY
2016-17, the assessee filed its return of income declaring income of Rs. 371,68,91,1...
Section 40A(2)(b) Disallowance Not Sustainable Where Both Assessee and Related Party Are Taxed at Same Rate – ITAT Delhi in Astra Management Services Pvt. Ltd. vs DCIT
Facts of the CaseThe assessee, Astra Management Services Pvt. Ltd., was engaged in trading
activities including purchase and sale of poppy seeds. During the relevant
assessment year, the assessee purchased poppy seeds ...
Nitrex Chemicals India Ltd. vs ACIT (ITAT Delhi): Disallowance on Repair & Maintenance Expenses Remanded for Verification – Capital vs Revenue Expenditure under Section 143(3)
Facts of the
CaseThe assessee, Nitrex Chemicals India Ltd., filed its return for Assessment Year 2016-17. The
assessment was completed by the Income
Tax Appellate Tribunal arising from the order passed by the Assessin...
ITAT Delhi: No Transfer Pricing Adjustment When Electricity Supplied Between Units at Market Rate – ACIT vs ACB India Ltd | Section 92CA & 80IA Case Law
Facts of the CaseThe appeal was filed by the Revenue before the Income Tax Appellate Tribunal, Delhi Bench
against the order passed by the Commissioner of Income Tax (Appeals) for Assessment Year 2014-15 in the case of
...
ITAT Delhi: Life Insurance Companies Taxable Only Under Section 44 – Additional Claim for Exemption u/s 10(15)(iv)(h) Can Be Raised Before ITAT | DCIT vs Max Life Insurance Co. Ltd
Facts of the
CaseThe assessee, Max Life Insurance
Co. Ltd, engaged in the business of life insurance, filed its return of income
for AY 2015-16 and AY 2016-17 declaring taxable income which was subsequently
enhanced ...
ITAT Delhi: Additions Beyond Scope of Limited Scrutiny Invalid; Notional Interest on CCDs Not Taxable – Sitac Re Pvt. Ltd vs DCIT (ITA No. 2237/Del/2019)
Facts of the CaseThe
assessee, Sitac Re Pvt. Ltd., is engaged in the business of installation and
sale of windmill projects and providing consultancy services related to wind
energy projects. The company also makes in...
ITAT Delhi: Additions Beyond Scope of Limited Scrutiny Invalid; Notional Interest on CCDs Not Taxable – Sitac Re Pvt. Ltd vs DCIT (ITA No. 2237/Del/2019)
Facts of the CaseThe
assessee, Sitac Re Pvt. Ltd., is engaged in the business of installation and
sale of windmill projects and providing consultancy services related to wind
energy projects. The company also makes in...
ITAT Delhi: Addition of Inter-Company Receivables Already Offered as Sales Amounts to Double Taxation – Paschimanchal Vidyut Vitran Nigam Ltd. vs DCIT (AY 2011-12)
Facts of the
CaseThe assessee, Paschimanchal Vidyut Vitran Nigam Ltd., is engaged in the business
of electricity distribution and is a 100%
subsidiary of Uttar Pradesh Power Corporation Limited (UPPCL). The
company c...