DOLPHIN DRILLING LIMITED,DEHRADUN vs. THE DEPUTY COMMISSIONER OF INCOME TAX, ( INTERNATIONAL TAXATION), DEHRADUN

ITA 52/DDN/2020Status: DisposedITAT Dehradun21 July 2026AY 2017-1814 pages
AI SummaryAllowed

What were the facts?

The assessee, Dolphin Drilling Limited, appealed against the taxability of an arbitral award and interest on delayed payments for AY 2015-16 and AY 2017-18. The Assessing Officer and CIT(A) had taxed these receipts as business income.

What did the Tribunal hold?

The Tribunal, following a previous decision for AY 2013-14 on identical issues, held that the arbitral award receipts and interest on delayed payments were not taxable in India. The Tribunal also noted that the issue of Permanent Establishment (PE) was raised by the assessee.

What were the issues?

Whether an arbitral award and interest on delayed payments are taxable as business income in India, and whether the assessee had a Permanent Establishment in India.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 44BB,Section 244A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘DB’, NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Appellant: Adv. Ms. Ananya Kapoor, Adv, CA Sh. Soumya Singh, Adv
For Respondent: DR (Virtual)
Hearing: 25.05.2026Pronounced: 21.07.2026

PER SATBEER SINGH GODARA, JM:

These assessee’s twin appeals i.e., ITA No. 5492/Del/2018 & 52/DDN/2020 for A.Y. 2015-16 & 2017-18 arise against the Commissioner of Income Tax(Appeals)-2 (for short, ’lea

The order continues below.

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