(International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd.

Commissioner of Income Tax (International Taxation-1), New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

The Commissioner of Income Tax (International Tax)-1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

The Commissioner of Income Tax (International Tax)-1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

The Commissioner of Income Tax (International Tax)-1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

The Commissioner of Income Tax (International Tax)-1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

The Commissioner of Income Tax (International Tax)-1 New Delhi vs. M/S Expeditors International of Washington Inc

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

…services that impart lasting technical benefits are classifiable as fees for technical services. It was on a consideration of the aforesaid that this court in Bio-Rad [CIT (International Taxation) v. Bio-Rad Laboratories (Singapore) Pte. Ltd., (2023) 459 ITR 5 (Delhi); 2023 SCC OnLine Del 6770.] had held that the real test would be the transfer of technical knowledge, the knowledge and skills and expertise of the provider being absorbed by the payer and who would then have the capability to deploy that knowledge or skill without reference to the original provider. This reinforces our view that the m…

Subodh Gupta, Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

…ITA No. 1264/DEL/2014 [A.Y. 2010-11] CEVA Freight LLC Vs. The Dy. D.I.T IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 1264/DEL/2014 [A.Y. 2010-11] CEVA Freight LLC Vs. The Dy. D.I.T 15350, Vickery Drive Circle – 1(1) Houston, Texas 77032 USA International Taxation ***** New Delhi KPMG, DLF Building No. 10 8th Floor, Tower B, DLF Cyber City Phase – 2, Gurgaon. PAN – AAHCM 2797 C (Applicant) (Respondent) Assessee By : Shri Salil Kapoor, Adv Shri Anil Chachra, Adv Department By : Shri Vizay B. Va…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 665/DEL/2025 [A.Y 2018-19] ITA No. 666/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada Corp. Vs. The Dy. C.I.T [resulted out of amalgamation of Pratt & Circle – 2(2)(2) Whitney Canada Corp and Turbo Engines Corp International Taxation 1000, Boul Marie Victorin, Longueuil New Delhi Quebec –J4G1A1 PAN – AAPCP 1595 F ITA No. 620/DEL/2025 [A.Y 2018-19] ITA No. 626/DEL/2025 [A.Y 2022-23] M/s Pratt & Whitney Canada (Sea) Pte Ltd Vs. The Dy. C.I.T 10, Loyang…

Harley-Davidson Motor Company Inc., United States of America vs. Assistant Commissioner of Income Tax, International Tax Circle- 2(1)(1), New Delhi

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishraharley – Davidson Motor Vs. Acit, International Tax Company Inc. Circle –2(1)(1), C/O. H-D Motor Company New Delhi India Pvt. Ltd. Building No.5, Tower A, Level-18, Dlf Cyber City Gurgaon, Haryana – 122 002 Pan : Aacch 6849 M (Appellant) (Respondent) Assessee By Shri K. M. Gupta, Adv. & Shri Jaskaran Sarkaria, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 26.11.2024 Date Of Pronouncement 27.12.2024 O R D E R Per Vimal Kumar, Jm:

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’ NEW DELHI BEFORE SHRI VIMAL KUMAR, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER Harley – Davidson Motor Vs. ACIT, International Tax Company Inc. Circle –2(1)(1), C/o. H-D Motor Company New Delhi India Pvt. Ltd. Building No.5, Tower A, Level-18, DLF Cyber City Gurgaon, Haryana – 122 002 PAN : AACCH 6849 M (Appellant) (Respondent) Assessee by Shri K. M. Gupta, Adv. and Shri Jaskaran Sarkaria, C.A. Respondent by Shri Vijay B. Vasanta, CIT-D.R. Date of Hearing 26.11.2024 Date of Pronouncement 27.12.2024 O R D E R PER VIMAL KUMAR, JM: 1. The…

Criteo Singapore Pte. Ltd., Singapore vs. ACIT Ciricle 1(2)(1) International Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

Bench: Shri Saktijit Dey & Shri Naveen Chandra

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘D’ BENCH, NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 2122/DEL/2023[A.Y. 2020-21]) CRITEO Singapore Pte. Ltd Vs. The A.C.I.T 138, Market Street, #34-01/02 Circle – 1(2)(1) Singapore New Delhi PAN – AAFCC 9817 M (Applicant) (Respondent) Assessee By : Shri S.K. Aggarwal, CA Shri Sarthak Bhandula, CA Department By : Shri Vijay B. Vasanta, CIT- DR Date of Hearing : 18.09.2024 Date of Pronouncement : 18.12.2024 ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred agai…

Invesco Uk Limited, Uk vs. ACIT, Circle Int.Tax. 2(1)(1), New Delhi

The appeals of the assessee are allowed

Bench: Sh. G.S. Pannu & Sh. Anubhav Sharma

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SH. G.S. PANNU, VICE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No.784 & 785/Del/2023 Assessment Year: 2020-21 Invesco Holding Company Vs. ACIT (US) Inc. C/o Invesco (India Circle Intl. Tax. 2 (1)(1) Private Limited), 15, Floor, New Delhi Block-6, North Tower, Divyasree Orion SEZ Raidurgam, Serilingampally Hyderabad, Hyderabad Telangana, 500032 PAN No.AAECI9027N (APPELLANT) (RESPONDENT) Appellant by Sh. Deepak Chopra, Advocate Sh. Ankul Goyal, Advocate Sh. Adwitya Grover, Advocate Respondent by Sh. Vizay B. Vasanta, CIT DR Date o…

Invesco Holding Company (Us) Inc., Usa vs. ACIT, Circle Int. Tax. 2(1)(1), New Delhi

The appeals of the assessee are allowed

Bench: Sh. G.S. Pannu & Sh. Anubhav Sharma

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SH. G.S. PANNU, VICE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No.784 & 785/Del/2023 Assessment Year: 2020-21 Invesco Holding Company Vs. ACIT (US) Inc. C/o Invesco (India Circle Intl. Tax. 2 (1)(1) Private Limited), 15, Floor, New Delhi Block-6, North Tower, Divyasree Orion SEZ Raidurgam, Serilingampally Hyderabad, Hyderabad Telangana, 500032 PAN No.AAECI9027N (APPELLANT) (RESPONDENT) Appellant by Sh. Deepak Chopra, Advocate Sh. Ankul Goyal, Advocate Sh. Adwitya Grover, Advocate Respondent by Sh. Vizay B. Vasanta, CIT DR Date o…

JCIT, Special Range-1, New Delhi vs. Axis Risk Consulting Services Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I” DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER I.T.A. No.2920/DEL/2018 Assessment Year 2012-13 JCIT, Special Range-1 Axis Risk Consulting Services P. Ltd. New Delhi Vs. Delhi Information Technology Park Shastri Park Delhi. TAN/PAN: AAECA9833G (Appellant) (Respondent) Appellant by: Shri Vishal Kalra, Adv. Shri Ankit Sahani, Adv. Mr. Yishu Goel, AR Respondent by: Dr. Anupama Singh, Sr.DR Date of hearing: 19 12 2023 Date of pronouncement: 14 02 2024 O R D E R PER PRADIP KUMAR KEDIA-A.M. : The captioned appeal is dir…