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Rolls-Royce Plc vs Deputy Director of Income Tax (International Taxation), New Delhi (2019) – Permanent Establishment, Section 9(1), Indo-UK DTAA
Facts of the CaseThe appellant, Rolls-Royce Plc, challenged a common order
passed by the Income Tax Appellate Tribunal (ITAT) concerning Assessment Years
2004–05 to 2009–10. The ITAT dismissed the appeals rel...
M/s Nestlé SA vs Assistant Commissioner of Income Tax (International Taxation), Circle-2(2)(2), New Delhi (Delhi High Court, 2019) – Reassessment u/s 147/148 Invalid When No Income Escaped Assessment & Return Filing Not Required u/s 115A(5)
Facts of the CaseThe Petitioner, M/s Nestlé SA, a tax resident of
Switzerland, earned income in India during AY 2011–12 in the form of dividend
and interest from its Indian subsidiary, Nestlé India Ltd. Tax was dul...
Rolls-Royce PLC vs Deputy Director of Income Tax (International Taxation) – Determination of Permanent Establishment (PE) in India under Section 9 of Income Tax Act & Indo-UK DTAA
Facts of the Case
Rolls-Royce
PLC (assessee) filed appeals against the Income Tax Appellate Tribunal
(ITAT) order for AYs 2004-05 to 2009-10.
ITAT
relied on an earlier Delhi High Court judgment (20...
PR. Commissioner of Income Tax-4, New Delhi vs Symphony Marketing Solutions India Pvt. Ltd. (Now Merged with Genpact India) – Delhi High Court | Exclusion of Infosys BPO as Comparable in Transfer Pricing
Facts of the CaseThe present matter concerns two appeals filed by the Revenue
against orders of the Income Tax Appellate Tribunal (ITAT) for Assessment Years
2009-10 and 2010-11. The assessee, Symphony Marketing Soluti...
Principal Commissioner of Income Tax-6 vs Nalwa Sons Investment Ltd. (Delhi High Court) – Section 14A, Section 73, Section 36(1)(vii), Section 68 | Speculative Loss & Bad Debt Write-off
Facts of the
Case
The case concerns appeals filed by the Revenue under Section
260A of the Income Tax Act, 1961 against the order of the ITAT.
The assessee, Nalwa Sons Investment Ltd., functioned primar...
PR. Commissioner of Income Tax-4, New Delhi vs Symphony Marketing Solutions India Pvt. Ltd. (Now Merged with Genpact India) – Delhi High Court | Transfer Pricing | Exclusion of Infosys BPO as Comparable
Facts of the
CaseThe present matter concerns appeals filed by the
Revenue before the Delhi High Court against the orders of the Income Tax
Appellate Tribunal (ITAT) dated 4th April 2017 and 18th August 2017 for
Asses...
Rolls-Royce PLC vs Deputy Director of Income Tax (International Taxation), New Delhi | Delhi High Court | Section 9(1), Indo-UK DTAA – Permanent Establishment (PE) Determination
Facts of the CaseThe appellant, Rolls-Royce PLC, challenged a common order of
the Income Tax Appellate Tribunal (ITAT) dated 28 May 2019 concerning
Assessment Years 2004-05 to 2009-10. The Tribunal had dismissed the ap...
Rolls-Royce Plc vs Deputy Director of Income Tax (International Taxation), Delhi High Court | Permanent Establishment under Section 9(1) & Indo-UK DTAA
Facts of the CaseThe present case pertains to appeals filed by Rolls-Royce
Plc (assessee) before the Delhi High Court against a common order of the Income
Tax Appellate Tribunal (ITAT) concerning Assessment Years 2004â...
The Pr. Commissioner of Income Tax Central-3 vs M/s Dreamcity Buildwell Pvt. Ltd. (Delhi High Court) – Section 153C Jurisdiction & Section 68 Unexplained Cash Credit
Facts of the
CaseThe assessee, M/s Dreamcity Buildwell Pvt. Ltd.,
engaged in real estate development, filed its return declaring NIL income for
AY 2005–06. The case was selected for scrutiny under Section 143(3).Dur...
Max Ventures Investment Holdings Pvt. Ltd. vs Income Tax Officer & Anr. (2019) – Reassessment u/s 147/148 Valid on Doubtful Share Application Money u/s 68 | Delhi High Court
Facts of the Case
The assessee company received ₹87 crores as share application
money from its promoter Shri Analjit Singh during FY 2009–10.
The return for AY 2010-11 was filed declaring minimal inc...