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Commissioner of Income Tax vs. Adidas India Marketing Pvt. Ltd. (Delhi High Court) Interest Payments on Foreign Loans & LIBOR Benchmarking under Section 37(1) of the Income Tax Act, 1961
Facts of the CaseThe Respondent-Assessee is a company incorporated
under the Indian Companies Act and a subsidiary of Adidas India Private
Limited, functioning as a joint venture between Adidas A.G. (Germany) and
Magn...
Commissioner of Income Tax vs. Singapore Airlines Ltd. & Others (2009) | Applicability of TDS Under Section 194H on Supplementary Commission and Concessional Tickets Issued to Travel Agents: Delhi High Court Judgment
Facts of the Case
The
Revenue preferred a batch of appeals against 12 airlines (including
Singapore Airlines, KLM Royal Dutch Airlines, British Airways, Air France,
Air India, and Lufthansa).
The
...
Commissioner of Income Tax vs. M/s. H.B. Stock Holdings Limited – Under Section 260A and Section 36(1)(iii) of the Income Tax Act, 1961
Facts
of the CaseThe Revenue filed an appeal against
the order of the Income Tax Appellate Tribunal (ITAT), which had ruled in favor
of the assessee, M/s. H.B. Stock Holdings Limited. The Assessing Officer (AO)
had m...
Commissioner of Income Tax vs. Magnum International Trading Company (P) Ltd. | Section 80HHC Deduction on Share Sale Profits and Interest Income – Delhi High Court
Facts of the CaseThe assessee, Magnum International Trading Company
(P) Ltd., claimed deduction under Section 80HHC on profits arising from export
activities. While computing such deduction, the assessee included profi...
Commissioner of Income Tax vs. France Air Pvt. Ltd. — Applicability of TDS under Section 194H on Supplementary Commission and Discounted Fares Paid by General Sales Agents (GSA) to IATA Agents
Facts of the Case
The
respondent-assessee acts as a General Sales Agent (GSA) for Air
France Ltd.
During
the Assessment Year 2002-03, the assessee passed on discounted fare
tickets to its Int...
Commissioner of Income Tax vs. Singapore Airlines Ltd. (Along with KLM Royal Dutch Airlines, British Airways, Air India, & Others) | Scope of Section 194H: Applicability of TDS on Supplementary Commission vs. Concessional Tickets
Facts of the Case
Reintroduction
of Section 194H: Section 194H was
reintroduced into the statute book via the Finance Act, 2001, effective
from 01.06.2001. The dispute primarily concerns the period fr...
Commissioner of Income Tax–XVII v. Gulf Air Company | Delhi High Court on TDS Liability under Section 194-I for Hotel Accommodation and Airport Navigation Charges
Facts of the CaseThe assessee, Gulf Air Company, a non-resident
airline operating flights between Bahrain and India, filed its return for
Assessment Year 2001-02. During assessment proceedings, the Assessing Officer
(...
Commissioner of Income Tax vs. M/s. H.B. Stock Holdings Limited – Under Section 260A and Section 36(1)(iii) of the Income Tax Act, 1961
Facts
of the CaseThe Revenue filed an appeal against
the order of the Income Tax Appellate Tribunal (ITAT), which had ruled in favor
of the assessee, M/s. H.B. Stock Holdings Limited. The Assessing Officer (AO)
had m...
Commissioner of Income Tax-VI, New Delhi vs The Motor & General Finance Ltd. & Connected Appeals | Whether Interest on Refund Already Paid Entitles Assessee to Interest on Interest under Sections 240, 243 & 244A of the Income-tax Act, 1961
Facts of the CaseThe appeals before the Delhi High Court were filed
by various assessees including The Motor & General Finance Ltd., MGF India
Ltd., Goodwill (India) Ltd., and MGM (India) Ltd. The common issue invo...
Commissioner of Income Tax vs. [Assessee] | Section 80HHC Deduction: Manufacturing Jewellery via Job Work Under Direction and Control Constitutes 'Manufacturer'
Facts
of the CaseThe appellant (Revenue) challenged
the concurrent findings of the lower tax authorities regarding the eligibility
of the assessee for export benefits. The assessee was engaged in the export of
gold j...