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Commissioner of Income Tax vs. [Respondent Name Not Available in Uploaded Order] – Appeal Dismissed on Account of Low Tax Effect under CBDT Instruction No. 5/2008 (Delhi High Court)
Facts
of the CaseThe Revenue filed Income Tax
Appeal No. 680/2009 before the Delhi High Court. The matter was heard along
with several connected appeals, namely ITA No. 430/2009, ITA No. 681/2009, ITA
No. 328/2009 an...
Commissioner of Income Tax v. Gujarat Guardian Limited: Deferral vs. Immediate Revenue Deductions under Sections 37(1), 36(1)(iii), and 43B(d) of the Income Tax Act, 1961
Facts of the CaseThe case arose from an appeal filed by the Revenue against the
order of the Income Tax Appellate Tribunal (ITAT) concerning the assessment
year 1996-97 for the respondent-assessee, M/s Gujarat Guardian...
Commissioner of Income Tax vs. Gujarat Guardian Limited | Dismissal of Revenue's Appeal Under Section 260A of the Income Tax Act, 1961 For Assessment Year 1996-97 in View of Connected Precedent ITA No. 669/2008
Facts of the CaseThe Appellant (Commissioner of Income Tax / Revenue) filed a
statutory tax appeal under Section 260A of the Income Tax Act, 1961. The appeal
challenged the validity of the appellate judgment and order ...
Commissioner of Income Tax Vs. [Respondent Party Name] | Maintainability of Tax Appeal Absent COD Approval Under Section 260A of the Income Tax Act, 1961 (2009:DHC:9878-DB)*
Facts of the Case
The Revenue (Income Tax Department) filed an appeal (ITA No.
89/2009) before the Hon’ble High Court of Delhi against an order passed
under the Income Tax Act, 1961.
Along with the appe...
Commissioner of Income Tax vs. Gangour Investment Ltd. – Deletion of Section 68 Share Application Money Addition on Failure of Revenue to Disprove Identity and Creditworthiness of Corporate Investor
Facts of the CaseThe assessee, Gangour Investment Ltd. (a member of
the National Stock Exchange engaged in the purchase and sale of shares), filed
its Income Tax Return for the Assessment Year 1996-97, declaring a loss...
Delhi High Court Ruling on Tax Deductibility of Corporate Club Membership: Commissioner of Income Tax vs. Samtel Color Limited (ITA 1152/2008)
Facts of the CaseThe assessee, M/s Samtel Color Limited, paid
corporate membership fees to India Habitat Centre (₹5 lakhs) and Sports &
Cultural Club, Noida (₹1 lakh), totaling ₹6 lakhs during the assessment ...
Director of Income Tax, New Delhi vs. Sheraton International Inc. — High Court of Delhi Judgement on the Taxability of Composite Fees as Business Profits vs. Royalty and Fees for Included Services under the Indo-USA Double Taxation Avoidance Agreement (DTAA)
Facts of the Case
The
Assessee: Sheraton International Inc. is a
company incorporated in the USA and a non-resident under Indian tax laws,
specializing in providing global hospitality and hotel-relate...
Director of Income Tax, New Delhi vs. Sheraton International Inc.: Whether Composite Fees Received by a Non-Resident for Global Marketing, Publicity, and Centralized Reservation Services Constitute Taxable Royalty/Fees for Included Services or Exempt Business Profits under the Indo-USA DTAA in the Absence of a Permanent Establishment
Facts of the Case
The assessee, Sheraton International Inc., is a company
incorporated in the USA and qualifies as a non-resident under Indian tax
laws. It specializes in providing comprehensive hospitality...
Director of Income Tax, New Delhi vs. Sheraton International Inc.
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a non-resident company incorporated under the laws
of the USA, specializing in providing comprehensive hotel-related
...
Director of Income Tax, New Delhi vs. M/s Sheraton International Inc.: Taxability of Integrated Global Marketing, Advertisement, and Reservation Services Under India-USA DTAA—Whether Receipts Constitute Business Profits in Absence of PE or Taxable as Royalty / Fee for Included Services (FIS) Under Section 9(1) of Income Tax Act, 1961
Facts of the Case
Assessee
Status: The assessee, Sheraton
International Inc., is a company incorporated in the USA and a
non-resident under Indian tax laws. It is engaged in providing worldwide
...