CIT v. Relx Inc.

Bombardier Inc., Quebec, Canada vs. Assistant Commissioner of Income Tax, Circle 1(1)(2), Delhi

In the result, the appeal of the Assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarbombardier Inc, Vs. Acit, 400, Dorval, Cote-Vertu, Circle-1(1)(2), Road West, Quebee Delhi Canada-H4S1Y9 (Appellant) (Respondent) Pan: Aaccb7177J Assessee By : Shri Sriram Seshadri, Cas Shri Varun Jain, Ca Shri Mohit Agarwal, Ca Ms. Amulya K. Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 10/12/2025

…ded services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied." 15. This court in a recent decision in Commissioner of Income-tax, International Taxation v. RELX Inc [2024] 160 taxmann.com 109/470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd. [2023] 155 taxmann.com 646/296 Taxman 167/459 ITR 5 (Delhi) and observed as under: 15. Similarly, in order for that income to fall within the ambit of "fees for included services", it was imperative for the Department to establish that the assessee was…

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…nt of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied.” 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT Page 11 of 25 ITA Nos. 665,666,620 & 626/DEL/2025 Pratt & Whitney Vs. DCIT v. Bio-Rad Laboratories (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department…

Pratt & Whitney Canada Corp., Canada vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…nt of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied.” 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT Page 11 of 25 ITA Nos. 665,666,620 & 626/DEL/2025 Pratt & Whitney Vs. DCIT v. Bio-Rad Laboratories (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department…

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…nt of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied.” 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT Page 11 of 25 ITA Nos. 665,666,620 & 626/DEL/2025 Pratt & Whitney Vs. DCIT v. Bio-Rad Laboratories (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department…

Pratt & Whitney Canada (Sea) Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2)(2), New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…nt of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied.” 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT Page 11 of 25 ITA Nos. 665,666,620 & 626/DEL/2025 Pratt & Whitney Vs. DCIT v. Bio-Rad Laboratories (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department…

The Commissioner of Income Tax - International Taxation -1 vs. Amazon Web Services, Inc

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…by the Supreme Court in Engg. Analysis Centre of Excellence (P) Ltd. v. CIT [Engg. Analysis Centre of Excellence (P) Ltd. v. CIT, (2022) 3 SCC 321 : (2021) 432 ITR 471] and have been noticed in Relx Inc. case [CIT v. Relx Inc., (2024) 3 HCC (Del) 229 : (2024) 470 ITR 611] and have been reproduced hereinabove. 12. We deem it appropriate to additionally observe that the right of subscription to a cloud-based software cannot possibly be said to be equivalent to the “use” or “right to use” any industrial, commercial or scientific equipment. This more so since the respondents sought to place the consideration received…

Pr. Commissioner of Income Tax, International Taxation-1, New Delhi vs. Goodrich Corporation

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

…ITA 173/2025 Page 1 of 14 $~23 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 23.05.2025 + ITA 173/2025, CM APPL. 31921/2025 & CM APPL. 31922/2025 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI .....Appellant Through: Mr Puneet Rai, SSC, Mr Ashvini Kumar and Mr Rishabh Nangia, JSCs and Mr Nikhil Jain, Advocate. versus GOODRICH CORPORATION .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) 1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [Act] impugning an order date…

Pr. Commissioner of Income Tax, International Taxation-1, New Delhi vs. Goodrich Corporation

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

…ITA 173/2025 Page 1 of 14 $~23 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 23.05.2025 + ITA 173/2025, CM APPL. 31921/2025 & CM APPL. 31922/2025 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI .....Appellant Through: Mr Puneet Rai, SSC, Mr Ashvini Kumar and Mr Rishabh Nangia, JSCs and Mr Nikhil Jain, Advocate. versus GOODRICH CORPORATION .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) 1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [Act] impugning an order date…

Anand Singh, Village Shahpur Turk vs. Income Tax Officer 69(5), Delhi

In the result, the appeal of the Assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarbombardier Inc, Vs. Acit, 400, Dorval, Cote-Vertu, Circle-1(1)(2), Road West, Quebee Delhi Canada-H4S1Y9 (Appellant) (Respondent) Pan: Aaccb7177J Assessee By : Shri Sriram Seshadri, Cas Shri Varun Jain, Ca Shri Mohit Agarwal, Ca Ms. Amulya K. Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 10/12/2025

…ded services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied." 15. This court in a recent decision in Commissioner of Income-tax, International Taxation v. RELX Inc [2024] 160 taxmann.com 109/470 ITR 611 had concurred with the view of this court in CIT v. Bio-Rad Laborataries (Singapore) Pte. Ltd. [2023] 155 taxmann.com 646/296 Taxman 167/459 ITR 5 (Delhi) and observed as under: 15. Similarly, in order for that income to fall within the ambit of "fees for included services", it was imperative for the Department to establish that the assessee was…

Parvinder Kaur Sawhney, Gurgaon vs. Pr, CIT, Delhi -12, New Delhi

In the result, assessee’s appeals in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

…nt of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied.” 15. This court in a recent decision in CIT v. Relx Inc.: (2024) 470 ITR 611 had concurred with the view of this court in CIT Page 11 of 25 ITA Nos. 665,666,620 & 626/DEL/2025 Pratt & Whitney Vs. DCIT v. Bio-Rad Laboratories (Singapore) Pte. Ltd.: (2023) 459 ITR 5 and observed as under: 15. Similarly, in order for that income to fall within the ambit of “fees for included services”, it was imperative for the Department…