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Commissioner of Income Tax (International Taxation)-2 vs ZTE Corporation (Delhi High Court) – No Royalty on Software Supply under DTAA | Section 9(1)(vi) & Section 234B Analysis
Facts of the CaseThe present appeals were filed by the Revenue against a common
order dated 15.02.2019 passed by the Income Tax Appellate Tribunal concerning
Assessment Years 2013-14 and 2015-16. The dispute involved t...
Pyramid IT Consulting Pvt. Ltd. vs Additional Commissioner of Income Tax (Delhi High Court, 2019) – Transfer Pricing Adjustment & Comparable Selection under Section 92C & 254(2) of Income Tax Act
Facts of the
Case
The assessee, engaged in IT solutions and staffing services, filed
return for AY 2010–11 declaring income and paid tax under Section 115JB.
The Assessing Officer referred the matter ...
PeopleStrong Technologies Pvt. Ltd. vs Assistant Commissioner of Income Tax, Circle 19(2), Delhi & Anr. | Delhi High Court on TDS Refund Release and Interest Claim under Income Tax Act
Facts of the CaseThe petitioner, PeopleStrong Technologies Private Limited,
filed writ petitions before the Delhi High Court seeking directions against the
Income Tax Department for release of refunds arising out of ex...
Assistant Commissioner of Income Tax (ACIT) vs V.K. Gupta (2020) – No Willful Default under Section 276CC Income Tax Act despite Delay in Filing Return
Facts of the
CaseThe present matter arose from prosecution initiated
by the Income Tax Department against the respondent for alleged failure to file
income tax returns pursuant to notices issued under Section 153A of ...
Ericsson India Private Limited vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1), 143(2), 241A & 143(1D) of Income Tax Act
Facts of the
CaseThe Petitioner, Ericsson India Private Limited,
engaged in telecommunication equipment business, filed income tax returns for
multiple Assessment Years (AY 2016–17, 2017–18, 2018–19), claiming s...
Commissioner of Income Tax (International Taxation)–3 vs Rolls Royce PLC (Delhi High Court, 2020) – Attribution of Profits to Permanent Establishment Restricted to 35%
Facts of the
CaseThe appeals were filed by the Revenue against a
common order dated 28.05.2019 passed by the Income Tax Appellate Tribunal
(ITAT), New Delhi concerning Assessment Years 2004-05, 2006-07, 2007-08, and
...
Commissioner of Income Tax (International Taxation)-3 vs Rolls Royce PLC (Delhi High Court, 2020) – Attribution of Profits to Permanent Establishment Restricted to 35%
Facts of the
CaseThe Revenue filed multiple appeals before the Delhi
High Court challenging a common order passed by the Income Tax Appellate
Tribunal (ITAT) concerning Assessment Years 2004-05, 2006-07, 2007-08, and
...
Ericsson India Private Limited vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1), 143(2), 241A & 143(1D) of Income Tax Act
Facts of the
CaseThe Petitioner, Ericsson India Private Limited,
engaged in telecommunication equipment business, filed income tax returns for
multiple Assessment Years (AY 2016–17, 2017–18, 2018–19), claiming s...
Ericsson India Private Limited vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1D) & 241A of Income Tax Act
Facts of the
Case
The petitioner, Ericsson India Pvt. Ltd., engaged in telecom
equipment business, filed returns for AY 2016-17, 2017-18, and 2018-19
claiming substantial refunds due to excess TDS deductio...
Ericsson India Pvt. Ltd. vs Additional Commissioner of Income Tax & Anr. (Delhi High Court, 2020) – Refund Withholding under Sections 143(1), 143(2), 143(1D) & 241A of Income Tax Act
Facts of the
CaseThe Petitioner, Ericsson India Pvt. Ltd.,
engaged in telecom equipment manufacturing and services, filed returns for AY
2016-17, 2017-18, and 2018-19 claiming substantial refunds due to excess TDS
de...