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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...
Kapoor Industries Limited vs Deputy Commissioner of Income Tax & Ors (2022) – Reassessment Notice Quashed for Violation of Natural Justice under Section 148 Income Tax Act
Facts of the
CaseThe petitioner, Kapoor Industries Limited,
filed writ petitions challenging reassessment notices dated 30 March 2021
issued under Section 148 for Assessment Years 2015–16, 2016–17, and 2017–18,
...
Commissioner of Income Tax (International Taxation)-2 vs MOL Corporation | Delhi High Court | Royalty Taxability & ITAT Remand Infructuous | ITA 419/2019
Facts of the
CaseThe present appeal was filed by the Revenue
challenging the order of the Income Tax Appellate Tribunal (ITAT), wherein the
Tribunal had remanded the matter back to the Assessing Officer (AO) for
fres...
Kapoor Industries Limited vs Deputy Commissioner of Income Tax & Ors (Delhi High Court, 2022) – Reassessment Invalid Due to Violation of Natural Justice under Sections 147 & 148 of Income Tax Act
Facts of the CaseThe petitioner, Kapoor Industries Limited, filed writ
petitions challenging reassessment notices dated 30 March 2021 issued under
Section 148 for Assessment Years 2015–16, 2016–17, and 2017–18, a...
Principal Commissioner of Income Tax, Delhi–07 vs. Punjab National Bank (Erstwhile United Bank of India) | Section 40(a)(ia) & Section 14A r/w Rule 8D | Delhi High Court (2022)
Facts of the
CaseThe Respondent/Assessee, Punjab National Bank
(erstwhile United Bank of India), filed its return of income for AY 2010–11
under Section 139(1) of the Income Tax Act, 1961. The case was selected for
...
Principal Commissioner of Income Tax, Delhi–07 vs. Punjab National Bank (Erstwhile United Bank of India) | Section 40(a)(ia) & Section 14A r/w Rule 8D | Delhi High Court (2022)
Facts of the
CaseThe Respondent/Assessee, Punjab National Bank
(erstwhile United Bank of India), filed its return of income for AY 2010–11
under Section 139(1) of the Income Tax Act, 1961. The case was selected for
...