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Celerity Infrastructure Pvt. Ltd. & Ors. vs Deputy Commissioner of Income Tax Circle 73(1), Delhi & Ors. | Delhi High Court | Rectification of Form-3 under DTVSV Act for Challan Head Error
Facts of the CaseThe petitioners, including Celerity Infrastructure Pvt. Ltd.
and other associated entities, filed declarations under the DTVSV Act through Forms
1 and 2 on 26 March 2021. However, while filing, they in...
Saif II Mauritius Company Limited & Anr. vs Assistant Commissioner of Income Tax Circle Int Tax 3(1)(2) Delhi & Anr. (2022:DHC:1112-DB)
Facts of the
CaseThe petitioners challenged reassessment notices
dated 30 March 2021 issued under Section 148 of the Income Tax Act for
Assessment Years 2016–17 and 2017–18. The notices were issued on the basis th...
PR. COMMISSIONER OF INCOME TAX-1 vs. M/S CONSORTIUM NUSSLI COMFORT NET | Section 143(2), 292BB & 124(3) IT Act | Non-Issue of Notice Cannot Be Cured by 292BB
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order dated 23rd March 2021 passed by the Income Tax Appellate Tribunal (ITAT)
for Assessment Year 2011–12. The core contention of the Reve...
PR Commissioner of Income Tax Central-II vs M/s Sharp Mint Limited (Delhi High Court) – No Addition under Section 153A in Absence of Incriminating Material
Facts of the CaseThe present appeal was filed by the Revenue challenging the
order of the Income Tax Appellate Tribunal (ITAT), which had dismissed the
Revenue’s appeal and deleted the disallowance of deduction under...
Qualcomm Technologies Inc. vs Deputy Commissioner of Income Tax (International Tax Circle 3-1-1) & Ors. – Delhi High Court Directs Grant of TDS Credit and Refund with Interest (AY 2013-14)
Facts of the CaseThe petitioner, Qualcomm Technologies Inc., filed a writ
petition seeking TDS credit and refund along with up-to-date interest for
Assessment Year 2013-14. The petitioner also requested directions to t...
Microsoft Regional Sales Corporation, USA vs Deputy Director of Income Tax & Connected Matters (MOL Corporation vs ACIT) – Royalty on Shrink-Wrapped Software | Delhi High Court (2022:DHC:1961-DB)
Facts of the
Case
The appeals involved Microsoft Regional Sales Corporation (USA)
and MOL Corporation challenging orders passed by tax authorities.
The central issue concerned whether payments received for
...
Commissioner of Income Tax (International Taxation)-2 vs Microsoft Corporation (Delhi High Court) – Software Licensing Not Royalty under Section 9(1)(vi)
Facts of the
CaseThe present appeals were filed by the Revenue under
Section 260A of the Income Tax Act, 1961 challenging the order of the Income
Tax Appellate Tribunal (ITAT) dated 13 May 2019 for Assessment Years 19...
Commissioner of Income Tax (International Taxation)-2 vs Microsoft Corporation (2022:DHC:1963-DB) – Software Licensing Not Royalty under Section 9(1)(vi) | Delhi High Court
Facts of the
CaseThe present appeals were filed by the Revenue under
Section 260A of the Income Tax Act, 1961 challenging the order of the
Income Tax Appellate Tribunal (ITAT) dated 13th May 2019 for Assessment Years
...
Commissioner of Income Tax (International Taxation)–2 vs MOL Corporation (Delhi High Court) – Remand Order, Royalty on Software & Infructuous Appeal under Indo-US DTAA
Facts of the
Case
The present appeal was filed by the Revenue
challenging the remand order passed by the Income Tax Appellate Tribunal
(ITAT). The ITAT had restored the matter to the Assessing Officer for fresh
ad...
Commissioner of Income Tax (International Taxation)-2 vs Microsoft Corporation (Delhi High Court) – Software Licensing Not Royalty u/s 9(1)(vi) | Section 260A Appeal Dismissed
Facts of the
CaseThe Revenue filed appeals under Section 260A
challenging the ITAT order dated 13 May 2019. The dispute pertained to whether
the income earned by Microsoft Corporation from licensing of software in Ind...