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LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Remand to DRP on Permanent Establishment Set Aside
Facts of the CaseThe appellant, LG Electronics Inc., Korea, challenged the
order of the Income Tax Appellate Tribunal (ITAT), which had remanded the
matter back to the Dispute Resolution Panel (DRP).The remand was spec...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax | Delhi High Court | Remand by ITAT on Permanent Establishment & Section 147/148 – Case Law Analysis
Facts of the
CaseThe appellant, LG Electronics Inc., Korea,
challenged the order of the Income Tax Appellate Tribunal (ITAT), which had
remanded the matter back to the Dispute Resolution Panel (DRP). The core issue
r...
Maple Logistics Private Limited & Anr. vs Principal Chief Commissioner of Income Tax & Ors (2019) – Refund Withholding under Section 241A Invalid Without Reasoned Order
Facts of the CaseThe petitioner company, engaged in multimodal logistics
services, faced financial hardship due to excess TDS deductions under Section
194C. Its business model involved low margins (less than 2%), while...
PR. Commissioner of Income Tax-4, Delhi vs Itochu India Private Limited (2019) – Transfer Pricing | ALP Determination under TNMM | Delhi High Court
Facts of the
CaseThe present matter involves three appeals filed by
the Revenue against separate orders of the Income Tax Appellate Tribunal (ITAT)
for Assessment Years 2007-08, 2008-09, and 2009-10. The assessee, Ito...
PR. Commissioner of Income Tax-7 vs. M/s Punjab and Sind Bank (2019) – Section 14A & Allowability of Contribution to Pension/Provident Fund Trust under Section 37
Facts of the CaseThe present appeals were filed by the Revenue against the
order of the Income Tax Appellate Tribunal (ITAT) dated 09.01.2019 concerning
Assessment Years 2011–12 and 2012–13. The ITAT dismissed the ...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court) – ITAT Cannot Remand When Facts Already on Record | Section 147/148 & Permanent Establishment
Facts of the
CaseThe appellant, LG Electronics Inc., Korea,
challenged the order of the Income Tax Appellate Tribunal (ITAT), which had
remanded the matter back to the Dispute Resolution Panel (DRP) for
determination...
PR. Commissioner of Income Tax-4 vs Agilis Information Technologies India Pvt. Ltd. & Anr. | Delhi High Court | Transfer Pricing Comparables | AY 2011-12
Facts of the
CaseThe present matter involved cross appeals filed
by both the Revenue and the Assessee against a common order passed by the
Income Tax Appellate Tribunal (ITAT) dated 13 November 2017 for Assessme...
PR. Commissioner of Income Tax-7 vs. Punjab and Sind Bank (Delhi High Court, 2019) – Allowability of Pension Fund Contribution & Section 14A Disallowance on Stock-in-Trade
Facts of the CaseThe present appeals were filed by the Revenue against the
order dated 09.01.2019 passed by the Income Tax Appellate Tribunal (ITAT)
concerning Assessment Years 2011–12 and 2012–13. The ITAT dismiss...
LG Electronics Inc., Korea vs Deputy Commissioner of Income Tax (Delhi High Court, 2020) – ITAT Remand Power & Permanent Establishment Determination
Facts of the
CaseThe appellant, LG Electronics Inc., Korea,
challenged the order of the Income Tax Appellate Tribunal (ITAT), which
remanded the matter to the Dispute Resolution Panel (DRP).The central controversy rev...
Pr. Commissioner of Income Tax–4 vs Agilis Information Technologies India Pvt. Ltd. & Connected Appeal | Delhi High Court | Transfer Pricing – Selection of Comparables | AY 2011–12
Facts of the
CaseThe present matter arises from two cross
appeals—one filed by the Revenue and the other by the Assessee—challenging a
common order dated 13 November 2017 passed by the Income Tax Appellate T...