Search Results for "double taxation exemption"

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Bombay High Court Allows Appeals by Acquiring Body in Land Acquisition Compensat...
Bombay High Court Dismisses NHAI Appeals in Land Acquisition Compensation Disput...
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Supreme Court Upholds Refusal to Eschew Proof Affidavit in Probate Proceedings. ...
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Search Results for "double taxation exemption"

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High Court

Bombay High Court Allows Revenue's Appeal in FII Capital Gains Tax Case — Remands to ITAT for Fresh Consideration of Article 24 DTAA Compliance. Interpretation of Article 24 of India-Singapore DTAA requires examination of whether capital gains were subject to tax in Singapore on receipt basis.

21 Jun 2023

The case involves an appeal by the Commissioner of Income Tax (IT) - 2 against an order of the Income Tax Appellate Tribunal (ITAT) dated 24 March 201...

High Court

Bombay High Court Upholds Tribunal's Restriction on Section 80HHB Deduction and Denial of Deduction for Foreign Tax Paid. The court held that only amounts transferred to Foreign Project Reserve Account during the previous year qualify for deduction under Section 80HHB, and tax paid abroad is not deductible under the Income Tax Act.

20 Dec 2016

The case involves an income tax reference by the Income Tax Appellate Tribunal to the Bombay High Court under Section 256(1) of the Income Tax Act, 19...

High Court

Bombay High Court Allows Revenue's Appeal in Slot Chartering Income Tax Case — Slot Chartering Income Not Exempt Under India-UK Tax Treaty. Income from slot chartering is taxable under Section 44B of the Income Tax Act, 1961, as it does not constitute 'operations of ships' under Article 9 of the India-UK Double Taxation Avoidance Agreement.

6 Aug 2012

The case involves two appeals by the Director of Income Tax (International Taxation) against a common order of the Income Tax Appellate Tribunal (ITAT...

High Court

Bombay High Court Dismisses Revenue's Appeal in Shipping Income Tax Case — Income from Operation of Ships in International Waters Not Taxable in India Under Article 8 of India-Singapore DTAA. The court held that the assessee, a Singapore tax resident, is not liable to tax in India on income from shipping operations as the DTAA allocates taxing rights to Singapore.

30 Aug 2023

The case involves an appeal by the Commissioner of Income Tax (International Taxation) against the order of the Income Tax Appellate Tribunal (ITAT) w...

High Court

Bombay High Court Allows Revenue Appeal in DEPB Taxation Case - Face Value of Duty Entitlement Passbook Chargeable Under Section 28(iiib) at Accrual, Excess Over Face Value Under Section 28(iiid) at Sale. The court held that the Tribunal erred in holding that the entire sale proceeds of DEPB are not profits under Section 28(iiid) and that face value should be deducted from sale proceeds.

28 Jun 2010

The appeal by the Revenue under Section 260A of the Income Tax Act, 1961 arose from a decision of the Special Bench of the Income Tax Appellate Tribun...

High Court

Bombay High Court Dismisses Assessee's Appeal in Income Tax Case on Dividend Distribution Tax Rate. DDT under Section 115-O is a tax on the company, not on shareholders, and the India-UK DTAA does not provide a lower rate for DDT.

27 Apr 2026

The Bombay High Court dismissed a batch of seven appeals filed by Foseco India Ltd. under Section 260A of the Income Tax Act, 1961, challenging a comm...

High Court

High Court of Karnataka Dismisses Revenue's Appeal in TDS Dispute — Payment to Non-Resident for Software Not Royalty Under Section 9(1)(vi) of Income Tax Act, 1961. Payment for shrink-wrapped software held to be for copyright article, not transfer of copyright rights, thus not taxable as royalty.

9 Mar 2015

The case involves two appeals filed by the Revenue (Commissioner of Income Tax and Deputy Commissioner of Income Tax (TDS)) against the common order o...

Supreme Court

Supreme Court Disposes of Appeals by Authority for Advance Rulings Against High Court Judgment Quashing AAR's Rejection of Treaty Benefits. Questions Raised on Taxation of Capital Gains Under India-Mauritius DTAA and Scope of Section 245R(2) Proviso (iii) of Income Tax Act, 1961.

1 Jan 1970

The disputes arose from applications for advance ruling filed by three Mauritius-incorporated companies—Tiger Global International II Holdings, Tige...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income Tax Act, 1961 for Non-Resident Company — Lack of Reasonable Belief of Income Escaping Assessment. Reassessment Based on Mere Change of Opinion is Impermissible; Notice and Order Rejecting Objections Set Aside.

13 Mar 2012

The petitioner, Indivest Pte Ltd, a company incorporated in Singapore and wholly owned by the Government of Singapore, filed a writ petition challengi...

High Court

High Court Dismisses Writ Petition in Income Tax Matter Involving India-China DTAA Interpretation. Petitioner's Claim for NIL Withholding Tax Certificate Rejected Due to Pending Assessments and Previous Tax Determinations Under Section 197 of Income Tax Act, 1961.

27 Mar 2026

The dispute involved a Chinese company, Petitioner, which provided technical services to its Indian subsidiary, Benteler India Private Limited, under ...

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