Iveco Spa v. ADIT

160 ITD 348Income Tax Appellate Tribunal#15061 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2025.

Sections most often in play

Section 5Section 12(5)Section 13Section 143(3)Section 144C(13)Section 144C(5)Section 271AASection 44DA

Judgments citing Iveco Spa v. ADIT

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

…onnection with PE would mean more than the mere possession by the PE of right or property but equal or little less than legal ownership of such right or property. He further made reference to the decision of this Tribunal in the case of 48. Iveco Spa vs ADIT: 160 ITD 348 (Del Trib.) wherein the assessee, an Italian company, had set up an Indian Branch Office, which was engaged in undertaking business development and liasoning activities in India. The assessee had entered into an agreement with another Indian company for technical collaboration and license for providing right to assemble diesel engines and its par…

PJSC STROYTRANSGAZ,NEW DELHI vs. DDIT, NEW DELHI

In the result the appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 6029/DEL/2012[2006-07]Status: DisposedITAT Delhi15 Apr 2019AY 2006-07

Bench: Shri N.K. Billaiya & Shri K.N. Charyita No. 2842/Del/2010 [A.Y: 2004-05]

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 115ASection 234BSection 44D

…e say of the ld. AR that it is an erroneous conclusion that no know-how has been provided by the Head Office at the time of bidding stage. 15. In support of its contention, the ld. AR relied upon the decision of the co-ordinate bench in the case of Iveco Spa 160 ITD 348 and ZTE Corporation 159 ITD 696. 16. Per contra, the ld. DR relied upon the findings of the lower authorities. 17. As explained elsewhere, the appellant company has participated in the following three projects: (i) Chennai Water Supply Augmentation Project; (ii) Iron Ore Slurry Pipeline Project; and (iii) Baroda-Ahemdabad Kalol Pipeline Projec…

DDIT, NEW DELHI vs. M/S. PJSC STROYTRANSGAZ, NEW DELHI

In the result the appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 3822/DEL/2010[2005-06]Status: DisposedITAT Delhi15 Apr 2019AY 2005-06

Bench: Shri N.K. Billaiya & Shri K.N. Charyita No. 2842/Del/2010 [A.Y: 2004-05]

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 115ASection 234BSection 44D

…e say of the ld. AR that it is an erroneous conclusion that no know-how has been provided by the Head Office at the time of bidding stage. 15. In support of its contention, the ld. AR relied upon the decision of the co-ordinate bench in the case of Iveco Spa 160 ITD 348 and ZTE Corporation 159 ITD 696. 16. Per contra, the ld. DR relied upon the findings of the lower authorities. 17. As explained elsewhere, the appellant company has participated in the following three projects: (i) Chennai Water Supply Augmentation Project; (ii) Iron Ore Slurry Pipeline Project; and (iii) Baroda-Ahemdabad Kalol Pipeline Projec…

DDIT, NEW DELHI vs. M/S. PJSC STROYTRANSGAZ, NEW DELHI

In the result the appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 3821/DEL/2010[2004-05]Status: DisposedITAT Delhi15 Apr 2019AY 2004-05

Bench: Shri N.K. Billaiya & Shri K.N. Charyita No. 2842/Del/2010 [A.Y: 2004-05]

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 115ASection 234BSection 44D

…e say of the ld. AR that it is an erroneous conclusion that no know-how has been provided by the Head Office at the time of bidding stage. 15. In support of its contention, the ld. AR relied upon the decision of the co-ordinate bench in the case of Iveco Spa 160 ITD 348 and ZTE Corporation 159 ITD 696. 16. Per contra, the ld. DR relied upon the findings of the lower authorities. 17. As explained elsewhere, the appellant company has participated in the following three projects: (i) Chennai Water Supply Augmentation Project; (ii) Iron Ore Slurry Pipeline Project; and (iii) Baroda-Ahemdabad Kalol Pipeline Projec…

PJSC STROYTRANSGAZ,NEW DELHI vs. DDIT, NEW DELHI

In the result the appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 2843/DEL/2010[2005-06]Status: DisposedITAT Delhi15 Apr 2019AY 2005-06

Bench: Shri N.K. Billaiya & Shri K.N. Charyita No. 2842/Del/2010 [A.Y: 2004-05]

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 115ASection 234BSection 44D

…e say of the ld. AR that it is an erroneous conclusion that no know-how has been provided by the Head Office at the time of bidding stage. 15. In support of its contention, the ld. AR relied upon the decision of the co-ordinate bench in the case of Iveco Spa 160 ITD 348 and ZTE Corporation 159 ITD 696. 16. Per contra, the ld. DR relied upon the findings of the lower authorities. 17. As explained elsewhere, the appellant company has participated in the following three projects: (i) Chennai Water Supply Augmentation Project; (ii) Iron Ore Slurry Pipeline Project; and (iii) Baroda-Ahemdabad Kalol Pipeline Projec…

PJSC STROYTRANSGAZ,NEW DELHI vs. DDIT, NEW DELHI

In the result the appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 2842/DEL/2010[2004-05]Status: DisposedITAT Delhi15 Apr 2019AY 2004-05

Bench: Shri N.K. Billaiya & Shri K.N. Charyita No. 2842/Del/2010 [A.Y: 2004-05]

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, Sr. DR
Section 115ASection 234BSection 44D

…e say of the ld. AR that it is an erroneous conclusion that no know-how has been provided by the Head Office at the time of bidding stage. 15. In support of its contention, the ld. AR relied upon the decision of the co-ordinate bench in the case of Iveco Spa 160 ITD 348 and ZTE Corporation 159 ITD 696. 16. Per contra, the ld. DR relied upon the findings of the lower authorities. 17. As explained elsewhere, the appellant company has participated in the following three projects: (i) Chennai Water Supply Augmentation Project; (ii) Iron Ore Slurry Pipeline Project; and (iii) Baroda-Ahemdabad Kalol Pipeline Projec…

Iveco Spa v. ADIT (160 ITD 348) — Cited in 6 Judgments | BharatTax