CIT v. Gulf Oil (Great Britain) Ltd.

108 ITR 874High Court#13215 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2011 to 2020.

Judgments citing CIT v. Gulf Oil (Great Britain) Ltd.

M/S. Voith Paper Gmbh, New Delhi vs. DDIT, New Delhi

In the result, appeal of the assessee is dismissed

ITA 1077/DEL/2014[2010-11]Status: DisposedITAT Delhi21 Feb 2020AY 2010-11

Bench: Shri O.P. Kant & Shri K.N. Charyassessment Year: 2010-11

Section 143(3)Section 144CSection 5(2)Section 9

…ail by various Courts in the following cases: • CIT Vs. R.D. Aggarwal & Co., 56 ITR (SC) • CIT Vs. Hindustan Shipyard Ltd., 109 ITR 158 (AP) • CIT vs. Atlas Steel Company Ltd., 164 ITR 401 (Cal.) • Commissioner of Income-tax Vs. Gulf Oil (Great Britain) Ltd., 108 ITR 874 (Bombay) 8.2 The ratio decidenci emanating from the aforesaid decision is that the following conditions should exist to constitute ‘Business Connection’ in India: • A real and intimate relation must exist between the trading activities carried on outside India by a non-resident and the activities in India; 69 Voith Paper GmbH • The relation co…

DCIT (It) 2(1)(2), Mumbai vs. Daimler Ag, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 183/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Mar 2019AY 2013-14

Bench: Shri Mahavir Singh, Jm & Shri G. Manjunatha, Am Dcit(It)-2(1)(2), Vs. M/S. Daimler Ag Room No.1612, 16Th Floor, C/O. Srbc & Associates Llp, Chartered Accountants, 14 Th Air India Building, Nariman Point Floor, The Ruby, 29, Senapati Mumbai – 400021 Bapat Marg, Dadar(W), Mumbai - 400028 Pan/Gir No. Aabcd2354C Appellant) .. Respondent)

Section 143(3)Section 5

…h part of the income as is reasonably attributable to the operations carried out in India- 9. The ld. Counsel for the assessee reiterated the arguments before the ld. CIT (A). He further relied on the following case laws: CIT Vs. Gulf Oil (Great Britain) Ltd. 108 ITR 874 (Bom) (Refer pg 56,62 of Paper Book-I) Mahabir Commercial Co Ltd vs. Commissioner of Income-tax (86 ITR 417) (SC); (Refer Pg 64, 80 of Paper Book) 6 M/s. Daimler AG Commissioner of Income-tax Vs Mewar Textile Mills Ltd (91 ITR 542) (SC); (Refer pg 81, 83 of Paper Book I) Additional Commissioner of income-tax v Skoda Export, Praha (172 ITR 358)…

DCIT (It) 2(1)(2), Mumbai vs. Daimler Ag (Formerly Known As Daimler Chrysler Ag), Mumbai

ITA 5704/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 May 2018AY 2011-12

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm Dcit (It)-2(1)(2), M/S Daimler Ag Room No. 1713, 17Th Floor, C/O Srbc & Associates Llp बिधम/ Air India Building, 14Th Floor, The Ruby, Nariman Point, 29 Senapati Bapat Marg, Vs. Mumbai-400021 Dadar (W), Mumbai-400050 स्थामी रेखा सं./ जीआइआय सं./ Pan No. Aabcd2354C (अऩीराथी /Revenue) (प्रत्मथी / Assessee) :

For Appellant: Shri M.P. Lohia &For Respondent: Shri V. Vidhyadhar, Sr. D.R
Section 143(2)Section 143(3)Section 5(2)Section 9(1)(i)

…h part of the income as is reasonably attributable to the operations carried out in India— 9. The ld. Counsel for the assessee reiterated the arguments before the ld. CIT (A). He further relied on the following case laws: CIT Vs. Gulf Oil (Great Britain) Ltd. 108 ITR 874 (Bom) (Refer pg 56,62 of Paper Book-I) Mahabir Commercial Co Ltd vs. Commissioner of Income-tax (86 ITR 417) (SC); (Refer Pg 64, 80 of Paper Book) Commissioner of Income-tax Vs Mewar Textile Mills Ltd (91 ITR 542) (SC); (Refer pg 81, 83 of Paper Book I) Additional Commissioner of income-tax v Skoda Export, Praha (172 ITR 358) (AP) (Refer pg 84, 8…

M/S Arrow Electronics India Ltd., Bangalore vs. Addl.DIT, Bangalore

In the result, the assesssee’s appeals are dismissed, the appeals of the Revenue and the Cross-Objections of the assessee are also dismissed

ITA 209/BANG/2011[2000-01]Status: DisposedITAT Bangalore31 Mar 2017AY 2000-01

Bench: Shri Sunil Kumar Yadav & Shri. S. Jayaraman

For Appellant: Shri. Gurunathan, AdvocateFor Respondent: Smt. Preethi Garg, CIT-DR
Section 148

…e assessee has relied on the following cases before the CIT(A): - CIT vs RD Aggarwal & Co (SC) [56 ITR 201 - CIT vs. Hindustan Shipyard Ltd (AP) [109 ITR 158] - CIT vs Atlas Steel Company Ltd (Cal) [164 .ITR 4011 - CIT vs Gulf Oil (Great Britain) Ltd (Bom) [108 ITR 874] -Imperial Chemical Industries Limited vs inspecting Assistant Commissioner [19 ITD 275] - VDO Tachometer Warke, West Germany vs CIT (Kar) [117 ITR 804] and the circular no 23 of the CBDT. After considering them, the CIT (A) held as under: “ 7.1 ……………………………………………………………………………………….- i. The CBDT has withdrawn circular no 3 dated 23.07.1969 along…

ADIT (It) (2), Mumbai vs. Daimler Ag, Mumbai

ITA 7648/MUM/2013[2008-09]Status: DisposedITAT Mumbai28 Sept 2016AY 2008-09

Bench: Shri R.C. Sharma, Am & Shri Sandeep Gosain, Jm आयकर अपील सं./ I.T.A. No. 7648 & 7649/Mum/2013 ("नधा"रण वष" / Assessment Year: 2008-09 & 2009-10) Asst. Dit(It) -1(2), M/S. Daimler Ag Room No.119, 1St Floor, Scindia C/O Srbc & Associates 14Th Floor, The Ruby 29, बनाम/ House, N.M. Road, Ballard Estate, Mumbai-400 038. Senapati Bapat Marg Vs. Dadar (West) Mumbai-400 028. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aabcd 2354C (अपीलाथ" /Appellant) (""यथ" / Respondent) :

For Appellant: Shri Hemen Chandariya
Section 143(3)Section 195Section 234B

…uch part of the income as is reasonably attributable to the operations carried out in India--- 9. The ld. Counsel for the assessee reiterated the arguments before the ld. CIT(A). he further relied on the following case laws: CIT v Gulf Oil (Great Britain) Ltd 108 ITR 874 (Bom) (Refer pg 56,62 of Paper Book-I) Mahabir Commercial Co Ltd vs. Commissioner of Income-tax (86 ITR 417) (SC); (Refer Pg 64, 80 of Paper Book) Commissioner of Income-tax vs Mewar Textile Mills Ltd (91 ITR 542) (SC); (Refer pg 81,83 of Paper Book I) Additional Commissioner of income-tax v Skoda Export, Praha (172 ITR 358) (AP) (Refer pg 84,88…

Director of Income Tax vs. Ericsson A.B., New Delhi

ITA-504/2007HC Delhi23 Dec 2011

…ement control or financial control or by way of sharing of profits for a business connection to come into existence. In support, he referred to the decision in the case of CIT Vs. Hindustan Shipyard Ltd. 109 ITR 158, CIT Vs. Gulf Oil Great Britain Ltd. 108 ITR 874 and Circular No.23 dated 23rd July, 1979. 33. His further submission was that the installation contractor also cannot be regarded as a business connection through which the assessee has earned any income in India, as the income of the assessee arises as a consequence of the supply contracts entered into with the cellular operator. There i…

Director of Income Tax

ITA/504/2007HC Delhi23 Dec 2011

…ement control or financial control or by way of sharing of profits for a business connection to come into existence. In support, he referred to the decision in the case of CIT Vs. Hindustan Shipyard Ltd. 109 ITR 158, CIT Vs. Gulf Oil Great Britain Ltd. 108 ITR 874 and Circular No.23 dated 23rd July, 1979. 33. His further submission was that the installation contractor also cannot be regarded as a business connection through which the assessee has earned any income in India, as the income of the assessee arises as a consequence of the supply contracts entered into with the cellular operator. There i…

CIT v. Gulf Oil (Great Britain) Ltd. (108 ITR 874) — Cited in 7 Judgments | BharatTax