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Search Results for "double tax avoidance agreement"

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High Court

Bombay High Court Examines Challenge to Advance Ruling on India-UAE DTAA and Revocable Trust Taxation. Writ Petitions Concern Taxability of Income from Indian Investments by UAE-Owned Trust Under Sections 61 and 63 of Income-tax Act, 1961 and Article 24 of India-UAE Tax Treaty.

28 Oct 2021

The matter before the Bombay High Court consisted of two writ petitions filed by Abu Dhabi Investment Authority (ADIA) and Equity Trust (Jersey) Limit...

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

High Court of Karnataka Dismisses Revenue's Appeal in Transfer Pricing Case — Assets Received from AE Not Taxable Under Section 28(iv) of Income Tax Act. The court held that assets received from Associated Enterprise without consideration are not taxable as perquisite under Section 28(iv) as they are not in the nature of 'benefit' arising from business or profession.

28 Jul 2025

The Revenue (Pr. Commissioner of Income Tax and Asst. Commissioner of Income Tax) filed an appeal under Section 260A of the Income Tax Act, 1961 again...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Case: Inland Haulage Charges Covered Under Article 8 of India-Belgium DTAA. The Court held that income from inland transport of cargo to port for international shipping is part of shipping income and not taxable as business profits.

17 Jul 2014

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

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 Allows Revenue's Appeal in Shipping Company Tax Case — Reimbursement of Telecommunication Costs Held as Income. Payments received by foreign shipping company from Indian agents for use of MaerskNet system treated as revenue receipt, not mere reimbursement, under Income Tax Act, 1961.

29 Apr 2015

The case involves a set of appeals filed by the Director of Income Tax against the order of the Income Tax Appellate Tribunal (ITAT) regarding the tax...

High Court

High Court of Bombay at Goa Examines Appeal Against BFAR Ruling on DDT Rate Under India-UK DTAA. Appellant Seeks Restriction of Dividend Distribution Tax to 10% Tax Treaty Rate on Dividends Paid to UK Parent Company.

28 Nov 2025

The appellant, M/s. Colorcon Asia Pvt. Ltd., an Indian company and wholly owned subsidiary of Colorcon Limited, United Kingdom, filed an appeal under ...

High Court

Karnataka High Court Allows Revenue's Appeal in ITC Hotels TDS Case — Remittances to US Company for Marketing Services Held Subject to TDS Under Section 195 of Income Tax Act. The court held that the existence of a permanent establishment is a factual issue and the assessee cannot rely on past No Objection Certificates to avoid TDS liability.

15 Jun 2015

The case involves appeals filed by the Commissioner of Income Tax and the Income Tax Officer (TDS) against the order of the Income Tax Appellate Tribu...

High Court

Bombay High Court Allows Appeal of Non-Resident Company in Tax Case, Holds That 'Assessee Aggrieved' Includes Any Party Adversely Affected by CIT(A) Order Under Section 253(1) of Income Tax Act, 1961. The Court set aside the Tribunal's dismissal on maintainability and remanded for merits.

27 Nov 2013

The appellant, M/s. Maersk BV (formerly Nedlloyd BV), a company incorporated in the Netherlands and tax resident there, was engaged in operating ships...

High Court

Karnataka High Court Allows Revenue's Appeal in ITC Hotels TDS Case — Remittances to US Company for Marketing Services Held Subject to TDS Under Section 195 of Income Tax Act, 1961. The court held that the assessee was liable to deduct tax at source on payments to a non-resident for services rendered outside India, as the income was deemed to accrue or arise in India under Section 9(1)(i), and the principle of consistency did not bar the Revenue from taking a different view.

15 Jun 2015

The case involves appeals by the Commissioner of Income Tax and the Income Tax Officer (TDS) against the order of the Income Tax Appellate Tribunal (I...

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