27. In Arabian Express Line Ltd. of United Kingdom v. Union of India

212 ITR 31High Court1995#13747 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2020 to 2025.

Sections most often in play

Section 13(4)Section 13(4A)Section 143(2)Section 143(3)Section 144CSection 153Section 234DSection 24A

Judgments citing 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India

Fullerton Financial Holdings Pte. Ltd., Singapore vs. The Assistant Commissioner of Income-Tax - (International Taxation), Circle 2(3)(1) - Mumbai, Mumbai

ITA 1137/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 153

…017] 390 ITR 427(Guj) (refer to Page Nos. 406 to 414 of the legal PB); • CIT v/s. Lakshmi Textile Exporters Ltd. (2000) 245 ITR 521 (Mad) (refer to Page Nos. 415 to 416 of the legal PB), • Arabian Express Line Ltd. of United Kingdom vis. Union of India (1995) 212 ITR 31 (Guj) (refer to Page Nos. 417 to 421 of the legal PB) 24 ITA No.1137/Mum/2025; A.Y. 2022-23 Fullerton Financial Holdings Pte. Ltd. 38. In fact, the Hon'ble Punjab and Haryana High Court in the case of Serco (Supra) held that a refusal to accept the validity of a certificate issued by the Contracting States would be contrary to the convention and…

Essar Communications Limited, Mauritius vs. ACIT, Circle-1 (2)(2), New Delhi

ITA 340/DEL/2022[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri N. Venkatraman, ASG
Section 250Section 253Section 6(3)

…ed by the Appellate Authorities and the court." 26. It also approved of the correctness of Circular No. 333 dated 2.4.1982 issued by the Central Board of Direct Taxes on the subject. 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India [(1995) 212 ITR 31 (Guj)] the Gujarat High Court, interpreting Section 90, in the light of Circular No. 333 dated 2-4-1982 issued by CBDT, held that the procedure of assessing the income of an NRI because of his occasional activities in establishing a business in India would not be applicable in a case where there is a convention between the Government of India and…

The Commissioner of Income Tax - International Taxation -3 vs. Telstra Singapore Pte Ltd

ITA/334/2022HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…Page 86 of 149 agreement prevail over the provisions of this Act and can be enforced by the Appellate Authorities and the court.‖ xxxx xxxx xxxx 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India [(1995) 212 ITR 31 (Guj)] the Gujarat High Court, interpreting Section 90, in the light of Circular No. 333 dated 2-4-1982 issued by CBDT, held that the procedure of assessing the income of an NRI because of his occasional activities in establishing a business in India would not be applicable in a case where there is a convention between the Government of India…

The Commissioner of Income Tax - International Taxation -3 vs. Telstra Singapore Pte Ltd

ITA/206/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…Page 86 of 149 agreement prevail over the provisions of this Act and can be enforced by the Appellate Authorities and the court.‖ xxxx xxxx xxxx 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India [(1995) 212 ITR 31 (Guj)] the Gujarat High Court, interpreting Section 90, in the light of Circular No. 333 dated 2-4-1982 issued by CBDT, held that the procedure of assessing the income of an NRI because of his occasional activities in establishing a business in India would not be applicable in a case where there is a convention between the Government of India…

The Commissioner of Income Tax - International Taxation -3 vs. Telstra Singapore Pte Ltd

ITA/61/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…Page 86 of 149 agreement prevail over the provisions of this Act and can be enforced by the Appellate Authorities and the court.‖ xxxx xxxx xxxx 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India [(1995) 212 ITR 31 (Guj)] the Gujarat High Court, interpreting Section 90, in the light of Circular No. 333 dated 2-4-1982 issued by CBDT, held that the procedure of assessing the income of an NRI because of his occasional activities in establishing a business in India would not be applicable in a case where there is a convention between the Government of India…

The Commissioner of Income Tax - International Taxation -3 vs. Telstra Singapore Pte Ltd

ITA/55/2023HC Delhi24 Jul 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 9

…Page 86 of 149 agreement prevail over the provisions of this Act and can be enforced by the Appellate Authorities and the court.‖ xxxx xxxx xxxx 27. In Arabian Express Line Ltd. of United Kingdom v. Union of India [(1995) 212 ITR 31 (Guj)] the Gujarat High Court, interpreting Section 90, in the light of Circular No. 333 dated 2-4-1982 issued by CBDT, held that the procedure of assessing the income of an NRI because of his occasional activities in establishing a business in India would not be applicable in a case where there is a convention between the Government of India…

Shri Prashant Trivedi, Prop. of Kudos Shipping Corporation, Bhavnagar vs. The Income Tax Officer, International Taxation, Gandhidham

In the result, both the appeals of the assessee are allowed

ITA 572/RJT/2012[2010-11]Status: DisposedITAT Rajkot20 Jan 2020AY 2010-11
For Appellant: Shri Kalpesh Doshi, A.RFor Respondent: Shri Anil Kumar Das, D.R
Section 163(2)Section 172Section 234B

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT Before: Shri Mahavir Prasad, Judicial Member and Shri Amarjit Singh, Accountant Member [Conducted through E-Court at Ahmedabad] ITA Nos. 572 & 573/Rjt/2012 Assessment Year 2010-11 Shri Prashant Trivedi, The ITO, Prop. of Kudos Shipping International Taxation, Corporation, M.V.Lucky Vs Gandhidham Arrow-Name of Vessel, (Respondent) Nr. Ambaji Vad Temple, Railways Station Road, Bhavnagar-364001 PAN: ADIPT7909A (Appellant) Revenue by: Shri Anil Kumar Das, D.R. Assessee by: Shri Kalpesh Doshi, A.R. Date of hearing : 07-01-2020 Date of pronouncement…