How many judgments cite (i) Formula One World Championship Ltd. v. CIT?

200 judgments on BharatTax cite (i) Formula One World Championship Ltd. v. CIT (394 ITR 80), spanning 2016 to 2026.

Which sections of the Income Tax Act does (i) Formula One World Championship Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 1961, Section 143(3), Section 144C(13), Section 234B, Section 270A, Section 234A.

(i) Formula One World Championship Ltd. v. CIT (394 ITR 80)

Q: What is (i) Formula One World Championship Ltd. v. CIT authority for?

This case provides foundational principles that illuminate the contours of the concept of 'Permanent Establishment' (PE) under tax treaties, especially regarding a 'fixed place' PE.

Dae (Sabs) Leasing Ireland 43 Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax Int Tax.Circle 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

ITA 1156/MUM/2025[2022-22]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-22

Section 143(3)Section 144C(13)Section 144C(5)

…ions, perused the material placed before us, examined the lease agreements and related correspondence, and considered the applicable law, including the principles laid down by the Hon‟ble Supreme Court in; i) Formula One World Championship Ltd. v. CIT [(2017) 394 ITR 80 (SC)], ii) E-Funds IT Solution Inc. v. CIT [(2018) 13 SCC 294], and the latest judgment of, iii) Hyatt International Southwest Asia Ltd. v. Addl. Director of Income Tax in Civil Appeal No. 9766 of 2015 (SC), all of which illuminate the contours of the concept of “Permanent Establishment” under tax treaties. The relevant principles laid down by the…

Dae (Sabs) 10296 Ireland Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax (Int Taxation), Cirlce 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

ITA 1155/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

Section 143(3)Section 144C(13)Section 144C(5)

…ions, perused the material placed before us, examined the lease agreements and related correspondence, and considered the applicable law, including the principles laid down by the Hon‟ble Supreme Court in; i) Formula One World Championship Ltd. v. CIT [(2017) 394 ITR 80 (SC)], ii) E-Funds IT Solution Inc. v. CIT [(2018) 13 SCC 294], and the latest judgment of, iii) Hyatt International Southwest Asia Ltd. v. Addl. Director of Income Tax in Civil Appeal No. 9766 of 2015 (SC), all of which illuminate the contours of the concept of “Permanent Establishment” under tax treaties. The relevant principles laid down by the…

Sky High Xliii Leasing Company Limited, Ireland vs. Assistant Commissioner of Income Tax Int Tax Circle 4 (2) (1) Mumbai, Mumbai

ITA 1122/MUM/2025[2022-2023]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-2023

Section 143(3)Section 144C(13)Section 144C(5)

…ore us, examined the lease agreements and related correspondence, and considered the applicable law, including the principles laid down 108 ITA No.1198/Mum/2025 and others by the Hon‟ble Supreme Court in; i) Formula One World Championship Ltd. v. CIT [(2017) 394 ITR 80 (SC)], ii) E-Funds IT Solution Inc. v. CIT [(2018) 13 SCC 294], and the latest judgment of, iii) Hyatt International Southwest Asia Ltd. v. Addl. Director of Income Tax in Civil Appeal No. 9766 of 2015 (SC), all of which illuminate the contours of the concept of “Permanent Establishment” under tax treaties. The relevant principles laid down by the…

Sunflower Aircraft Leasing Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 4(2)(2) International Tax, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 1107/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

Section 143(3)Section 144C(13)Section 144C(5)Section 9(1)(vi)

…he LD.DRP however was unconvinced and drawing heavily on the reasoning in Poompuhar Shipping Corporation Ltd. v. ITO [2014] 360 ITR 257 (Mad), and applying the disposal test articulated by the Supreme Court in Formula One World Championship Ltd. v. CIT (2017) 394 ITR 80 (SC), it held that: • The ownership of high-value, income-earning assets (aircraft) continuously located in India for commercial exploitation constituted a tangible presence in the source State. • The contractual rights to inspect and repossess the aircraft went beyond bare ownership, amounting to “ultimate control and exercisable disposal over th…

Ortus Aircraft Lease 6(Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

ITA 1106/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 143(3)Section 144C(13)Section 144C(5)

…ions, perused the material placed before us, examined the lease agreements and related correspondence, and considered the applicable law, including the principles laid down by the Hon‟ble Supreme Court in; i) Formula One World Championship Ltd. v. CIT [(2017) 394 ITR 80 (SC)], ii) E-Funds IT Solution Inc. v. CIT [(2018) 13 SCC 294], and the latest judgment of, iii) Hyatt International Southwest Asia Ltd. v. Addl. Director of Income Tax in Civil Appeal No. 9766 of 2015 (SC), all of which illuminate the contours of the concept of “Permanent Establishment” under tax treaties. The relevant principles laid down by the…

Hyatt International Southwest Aisa Ltd vs. Additional Director of Income Tax

The appeals are dismissed

C.A. No.-009766-009766 - 2025Supreme Court24 Jul 2025

Bench: This Court, Before The High Court & Before The Income

Section 142(1)Section 143(3)

…. Ltd, under a separate Hotel Operating Services Agreement (HOSA) entered into with the hotel owner. The appellant had no involvement in such daily management. However, the High Court erred in conflating the two separate legal agreements – the 8 (2018) 13 SCC 294 10 SOSA entered into by the appellant and the HOSA entered into by Hyatt India Pvt. Ltd. – and mistakenly attributed the day-to-day control of hotel operations to the appellant. According to the learned Senior Counsel, Hyatt India Pvt. Ltd. is a distinct legal entity, taxable independently under Indian law, and its operational activities…

Il&Fs Rail Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, appeals of the assesses are allowed, pro tanto

ITA 1288/DEL/2016[2011-12]Status: DisposedITAT Delhi17 Mar 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.994/िद"ी/2025(िन.व. 2022-23) Kosi Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaick-6199-B बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(2), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1027/िद"ी/2025(िन.व. 2022-23) Hoohly Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aafch-6609-C बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1070/िद"ी/2025(िन.व. 2022-23) Luni Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaecl-5180-H बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002

…ase agreements and related correspondence, and considered the applicable 87 ITA No.994/Del/2025 (A.Y.2022-23)& Other Group Appeals law, including the principles laid down by the Hon'ble Supreme Court in; (i) Formula One World Championship Ltd. v. CIT [(2017) 394 ITR 80 (SC) ], (ii) E- Funds IT Solution Inc. v. CIT [(2018) 13 SCC 294], and the latest judgment of, (iii) Hyatt International Southwest Asia Ltd. v. Addl. Director of Income Tax in Civil Appeal No. 9766 of 2015 (SC), all of which illuminate the contours of the concept of "Permanent Establishment" under tax treaties. The relevant principles laid down by…