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Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd – No Permanent Establishment & Software Payments Not Royalty under India–Singapore DTAA (Delhi High Court)
Facts of the
CaseThe present appeals were filed by the Revenue under
Section 260A of the Income Tax Act, 1961 before the Delhi High Court. The
dispute pertained to the taxability of income earned by Nortel Networks
S...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd (2018) – Delhi High Court | Permanent Establishment & Royalty under India–Singapore DTAA
Facts of the
Case
The Revenue filed appeals under Section 260A challenging orders in
favour of the assessee, Nortel Networks Singapore Pte Ltd.
The dispute involved cross-border transactions and applicability...
PR. COMMISSIONER OF INCOME TAX (CENTRAL-3) vs ABHISAR BUILDWELL PVT. LTD. – Section 153A – No Addition Without Incriminating Material – Delhi High Court
Facts of the CaseA search operation was conducted on 21st January 2011 in the
Dharampal Satyapal Group. Consequent to the search, notice under Section 153A
was issued to the assessee, Abhisar Buildwell Pvt. Ltd., which...
M/s McKinsey Knowledge Centre India Pvt. Ltd. vs Pr. Commissioner of Income Tax, Delhi-6 (Delhi High Court, 2019) – KPO vs Knowledge Management Services & Precedential Value under Income Tax Law
Facts of the CaseThe assessee, M/s McKinsey Knowledge Centre India Pvt.
Ltd., filed appeals against orders passed by the Income Tax Appellate
Tribunal (ITAT) for Assessment Years 2011–12 and 2012–13.The core disput...
Vikram Krishnan vs Principal Commissioner of Income Tax (Delhi High Court) – Section 2(22)(e) Deemed Dividend on Shareholder Advances
Facts of the CaseThe assessee, an individual deriving income from salary, house
property, capital gains, and interest, was a director and 50% shareholder in a
closely held company, M/s Charu Home Products (P) Ltd...
Commissioner of Income Tax (International Taxation) v. Nortel Networks Singapore Pte Ltd (2018) – Delhi High Court | Permanent Establishment & Royalty under India–Singapore DTAA
Facts of the
Case
The Revenue filed appeals under Section 260A challenging orders in
favour of the assessee, Nortel Networks Singapore Pte Ltd.
The dispute involved cross-border transactions and applicability...
M/s. McKinsey Knowledge Centre India Pvt. Ltd. vs Pr. Commissioner of Income Tax, Delhi-6 (Delhi High Court) – ITAT Findings on KPO Classification Not Binding as Precedent
Facts of the Case
The
assessee, M/s. McKinsey Knowledge Centre India Pvt. Ltd., filed
appeals against ITAT orders for AY 2011-12 and AY 2012-13.
The
ITAT had concluded that the assessee was engaged...
PR. Commissioner of Income Tax-5 vs Jindal Photo Ltd. (2018) – Delhi High Court | Low Tax Effect Appeal Dismissed Without Examining Merits
Facts of the
CaseAs observed from the order (Page 1–2), the Revenue
filed appeals (ITA 1337/2018, 1338/2018, 1341/2018) against the respondent
assessee, Jindal Photo Ltd. During the hearing, it was submitted by the ...
M/s Infonox Software Pvt. Ltd. & Ors. vs Deputy Commissioner of Income Tax (Delhi High Court, 2019) – Withdrawal of Petition with Liberty under Section 139(1) Income Tax Act
Facts of the CaseThe petitioners, M/s Infonox Software Private Limited &
Others, filed multiple criminal miscellaneous petitions before the Delhi
High Court challenging proceedings initiated by the Income Tax...
Pr. Commissioner of Income Tax-1, Chandigarh vs Parabolic Drugs Ltd. (Delhi High Court, 2019) – Condonation of Delay Rejected due to Government Lethargy under Income Tax Act
Facts of the Case
The
Revenue filed an appeal against the ITAT order dated 17 June 2011 for AY
2006–07.
There
was a delay of 928 days in filing the appeal and 1656 days in
re-filing the sam...