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GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT Order Set Aside for Non-Adjudication of Permanent Establishment (PE), Fees for Technical Services (FTS) and Attribution Issues under Sections 260A & 254(2) of the Income Tax Act, 1961
Facts of the
CaseThe assessee filed appeals before the ITAT
challenging tax treatment on several grounds involving installation Permanent
Establishment, attribution of profits, and taxability of technical service
inc...
Pr. Commissioner of Income Tax-6, New Delhi vs Monnet Ispat & Energy Ltd. | Delhi High Court on IBC Moratorium over Income Tax Appeals under Sections 14, 238 & 7 of Insolvency and Bankruptcy Code, 2016
Facts of the CaseThe Revenue Department, through the Principal Commissioner
of Income Tax, filed multiple appeals before the Delhi High Court challenging
the order passed by the Income Tax Appellate Tribunal (ITAT) con...
Pr. Commissioner of Income Tax-18 vs N. S. Software (Firm) | Delhi High Court on Scope of Additions in Section 153A Assessments in Light of Kabul Chawla Principle
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court concerning Assessment Years 2005-06 and 2006-07 against the
respondent assessee, N. S. Software (Firm). The dispute arose from assessment...
H.T. Media Limited Vs. Principal Commissioner of Income Tax-IV, New Delhi | Delhi High Court | Section 14A read with Rule 8D of Income Tax Rules | Disallowance of Interest & Administrative Expenditure on Exempt Income
Facts of the CaseH.T. Media Limited, engaged in printing and publishing
newspapers and periodicals, filed its return for AY 2008-09 declaring taxable
income.During the relevant assessment year:
The
assess...
MSD Pharmaceuticals Pvt. Ltd. Vs. Additional Commissioner of Income Tax & Anr. | Delhi High Court on Transfer Pricing Adjustment under Section 92CA – AMP Expenditure and Bright Line Test (AY 2011-12)
Facts of the
CaseThe present appeals were filed by the assessee, MSD
Pharmaceuticals Pvt. Ltd., pertaining to Assessment Year 2011–2012, involving
transfer pricing adjustments in relation to Advertisement, Marketing...
M/s Televista Electronics Ltd. vs Dy. Commissioner of Income Tax | Appealability of Rectification Orders under Section 154 and Levy of Interest under Section 220(2) of the Income Tax Act, 1961 | Delhi High Court
Facts of the
CaseThe assessee, M/s Televista Electronics Ltd.,
filed its return for Assessment Year 1989–90 declaring income of Rs.
12,05,070/-. During the original assessment proceedings under Section 143(3),
the ...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi – ITAT Order Set Aside for Non-Adjudication of Permanent Establishment (PE), Fees for Technical Services (FTS) and Attribution Issues under Sections 254(2) & 260A of the Income Tax Act, 1961
Facts of the
CaseThe assessee, GE Nuovo Pignone S.P.A., filed
appeals before the Delhi High Court under Section 260A challenging a common
order passed by the ITAT for Assessment Years 2001-02 to 2008-09.The grievance ...
Commissioner of Income Tax-II vs Mitsubishi Corporation India Pvt. Ltd. | Delhi High Court | Section 40(a)(i), Section 195, Section 260A of Income Tax Act | TDS on Payments to Non-Residents | DTAA Non-Discrimination Clause | Permanent Establishment (PE) Dispute
Facts of the CaseMitsubishi Corporation India Pvt. Ltd. was engaged
in international trade and procurement activities in India for the Mitsubishi
Group.For Assessment Year 2006-07:
The assessee filed its return decla...
H.T. Media Limited vs Principal Commissioner of Income Tax-IV, New Delhi Delhi High Court | ITA Nos. 548/2015 & 549/2015 | Assessment Year 2008–09 Section 14A read with Rule 8D of the Income-tax Act, 1961 – Disallowance of Expenditure in Relation to Exempt Income – Requirement of Recording Satisfaction by Assessing Officer
Facts of the CaseThe assessee, H.T. Media Limited, engaged in the
business of printing and publishing newspapers and periodicals, filed its
return for AY 2008–09 and claimed exempt dividend income amounting to ...
GE Nuovo Pignone S.P.A. vs Commissioner of Income Tax (International Taxation), Delhi-I | Delhi High Court on ITAT’s Failure to Adjudicate Installation PE, FTS Taxability and Attribution of Profits under Sections 260A & 254(2) of the Income Tax Act, 1961
Facts of the
CaseThe appellant-assessee, GE Nuovo Pignone S.P.A.,
filed appeals before the Delhi High Court challenging a common order passed by
the ITAT for Assessment Years 2001–02 to 2008–09. The grievance of t...