Engineering Analysis Centre for Excellence (P) Ltd. (supra); and CIT v. Telstra Singapore Pte. Ltd.

467 ITR 302High Court2024#25221 most cited
3

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

Judgments citing Engineering Analysis Centre for Excellence (P) Ltd. (supra); and CIT v. Telstra Singapore Pte. Ltd.

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. CLIFFORD CHANCE PTE LTD.

The appeals are dismissed

ITA/354/2025HC Delhi04 Dec 2025

Bench: Us Is For The Assessment Year (Ay) 2020-21 & I.T.A. 353/2025 Is For Ay 2021-22.

For Appellant: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., MrFor Respondent: Mr. Ajay Vohra, Senior Advocate with Mr
Section 143(3)Section 144C(13)Section 260A

…ns of the DTAA. To buttress this argument, he has referred to the judgments in DIT v. New Skies Satellite BV, [2016] 382 ITR 114 (Del)- approved in Engineering Analysis Centre for Excellence (P) Ltd. (supra); and CIT v. Telstra Singapore Pte. Ltd., [2024] 467 ITR 302 (Del). 26. Mr. Vohra stated that as such, the question of law (B) also needs to be answered in the negative and in favour of the respondent. 27. He has prayed that the appeals be dismissed. ANALYSIS AND CONCLUSION 28. Having heard the learned counsel for the parties and perused the record, at the outset, we may state that the issue tha…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. CLIFFORD CHANCE PTE LTD.

The appeals are dismissed

ITA/353/2025HC Delhi04 Dec 2025

Bench: Us Is For The Assessment Year (Ay) 2020-21 & I.T.A. 353/2025 Is For Ay 2021-22.

For Appellant: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., MrFor Respondent: Mr. Ajay Vohra, Senior Advocate with Mr
Section 143(3)Section 144C(13)Section 260A

…ns of the DTAA. To buttress this argument, he has referred to the judgments in DIT v. New Skies Satellite BV, [2016] 382 ITR 114 (Del)- approved in Engineering Analysis Centre for Excellence (P) Ltd. (supra); and CIT v. Telstra Singapore Pte. Ltd., [2024] 467 ITR 302 (Del). 26. Mr. Vohra stated that as such, the question of law (B) also needs to be answered in the negative and in favour of the respondent. 27. He has prayed that the appeals be dismissed. ANALYSIS AND CONCLUSION 28. Having heard the learned counsel for the parties and perused the record, at the outset, we may state that the issue tha…

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 vs. AMAZON WEB SERVICES, INC

ITA/150/2025HC Delhi29 May 2025

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

For Appellant: Mr. Ruchir Bhatia, SSC, Mr. Anant Mann, JSCFor Respondent: Mr. Porus Kaka, Sr. Advocate with Mr. Rohit Jain
Section 144C(13)Section 147Section 148Section 195Section 201Section 260ASection 9

…ived cannot be considered as royalties within the meaning of Article 12(3) of the India- US DTAA. This question is also stands covered by the decisions of this Court in Commissioner of Income-tax (International Taxation) v. Telstra Singapore Pte. Ltd.: (2024) 467 ITR 302, Asia Satellite Digitally Signed By:TARUN RANA Signing Date:29.05.2025 15:38:55 Signature Not Verified ITA Nos.150/2025 & 154/2025 Page 36 of 36 Telecommunications Co. Ltd. v. Director of Income-tax: (2011) 332 ITR 340, and Director of Income-tax v. New Skies Satellite BV & Anr.: (2016) 382 ITR 114. 48. In our view, no substantial question of l…

Engineering Analysis Centre for Excellence (P) Ltd. (supra); and CIT v. Telstra Singapore Pte. Ltd. (467 ITR 302) — Cited in 3 Judgments | BharatTax