46/228 Taxman 88 (Delhi) (Mag.); (ii) CIT v. Globus Securities & Finance Pvt. Ltd.

224 Taxmann 237High Court2014#3464 most cited

What is 46/228 Taxman 88 (Delhi) (Mag.); (ii) CIT v. Globus Securities & Finance Pvt. Ltd. authority for?

Cases involving share capital are distinguishable if the transactions were solely book adjustments and not actual cash receipts.

35

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

CIT v. Globus Securities & Finance Pvt. Ltd. · section 68 · share capital · share premium · cash credits · book adjustment · actual receipt · creditworthiness of creditor · source of source

Also reported as

41 Taxmann.com 465

Issues it is cited on

Judgments citing 46/228 Taxman 88 (Delhi) (Mag.); (ii) CIT v. Globus Securities & Finance Pvt. Ltd.

TELEFONICA UK LTD.,MUMBAI vs. DCIT (INT TAX), RANGE-4(1)(2), MUMBAI

In the result, on this ground, appeal of the assessee is treated as allowed

ITA 772/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Us On Merits Is With Regard To Ground No.11-19 Which Releates To Cellular Roaming Charges & Treating The Amount Of Rs.7,45,72,450/- Taxable Under 9(1)(Vi) Of The Act & Also As Per India-Uk Dtaa Under Article 13(3). At The Outset, Ld. Counsel For The Assessee Submitted That This Issue Stands Covered In The Case Of M/S. Telefonica Depreciation Espana Sa Vs. Cit In Ita No.2657/Bang/2019, 180/Bang/2022& 817/Bang/2022 For The A.Yrs. 2010-11 To 2012-13. 3. The Brief Facts Are That Assessee, I.E., Telefonica Uk Ltd Is A Company Incorporated Under The Laws Of United Kingdom Of Great Britain & Northern Ireland (Uk) & Is A Tax Resident Of Uk. The Assessee Is A Non-Resident Telecommunication Service Provider, Primarily Engaged In The Business Of Providing Mobile & Broadband Services Along With Various Other Ancillary Services Such As Text, Media Messaging, Games, Music, Video & Data Connections In The United Kingdom.

Section 144Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA No.771/Mum/2023 & 772/Mum/2023 (Assessment Year :2014-15) M/s. Telefonica UK Limited Vs. Deputy Commissioner 16th Floor, The Ruby of Income Tax 29, Senapati Bapat Marg (International Dadar (W) Taxation)-4(1)(2) Mumbai Mumbai Maharashtra-400 028 PAN/GIR No.AAICT7347J (Appellant) .. (Respondent) Assessee by Shri Hiten Chande Revenue by Shri S Anbuselvam Date of Hearing 29/08/2023 Date of Pronouncement 22/09/2023 आदेश / O R D E R PER AMIT SHUKLA (J.M): In so far as appeals…

TELEFONICA UK LTD.,MUMBAI vs. DCIT (INT TAX), RANGE-4(1)(2), MUMBAI

In the result, on this ground, appeal of the assessee is treated as allowed

ITA 771/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Us On Merits Is With Regard To Ground No.11-19 Which Releates To Cellular Roaming Charges & Treating The Amount Of Rs.7,45,72,450/- Taxable Under 9(1)(Vi) Of The Act & Also As Per India-Uk Dtaa Under Article 13(3). At The Outset, Ld. Counsel For The Assessee Submitted That This Issue Stands Covered In The Case Of M/S. Telefonica Depreciation Espana Sa Vs. Cit In Ita No.2657/Bang/2019, 180/Bang/2022& 817/Bang/2022 For The A.Yrs. 2010-11 To 2012-13. 3. The Brief Facts Are That Assessee, I.E., Telefonica Uk Ltd Is A Company Incorporated Under The Laws Of United Kingdom Of Great Britain & Northern Ireland (Uk) & Is A Tax Resident Of Uk. The Assessee Is A Non-Resident Telecommunication Service Provider, Primarily Engaged In The Business Of Providing Mobile & Broadband Services Along With Various Other Ancillary Services Such As Text, Media Messaging, Games, Music, Video & Data Connections In The United Kingdom.

Section 144Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA No.771/Mum/2023 & 772/Mum/2023 (Assessment Year :2014-15) M/s. Telefonica UK Limited Vs. Deputy Commissioner 16th Floor, The Ruby of Income Tax 29, Senapati Bapat Marg (International Dadar (W) Taxation)-4(1)(2) Mumbai Mumbai Maharashtra-400 028 PAN/GIR No.AAICT7347J (Appellant) .. (Respondent) Assessee by Shri Hiten Chande Revenue by Shri S Anbuselvam Date of Hearing 29/08/2023 Date of Pronouncement 22/09/2023 आदेश / O R D E R PER AMIT SHUKLA (J.M): In so far as appeals…

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