Planetcast International Pte. Ltd. v. ACIT

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES SINGAPORE PTE LTD. (EARLIER KNOWN AS HP SERVICES SINGAPORE PTE LTD.)

The appeals are dismissed against the

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES SINGAPORE PTE LTD. (EARLIER KNOWN AS HP SERVICES SINGAPORE PTE LTD.)

The appeals are dismissed against the

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES (SINGAPORE) PTE LTD. (EARLIER KNOWN AS HP SERVICES (SINGAPORE) PTE LTD.)

The appeals are dismissed against the

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES SINGAPORE PTE LTD. (EARLIER KNOWN AS HP SERVICES SINGAPORE PTE LTD.)

The appeals are dismissed against the

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES (SINGAPORE) PTE LTD. (EARLIER KNOWN AS HP SERVICES (SINGAPORE) PTE LTD.)

The appeals are dismissed against the

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs. DXC TECHNOLOGY SERVICES SINGAPORE PTE LTD. (EARLIER KNOWN AS HP SERVICES SINGAPORE PTE LTD.)

The appeals are dismissed against the

…aken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co- ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards in…

INVESCO HOLDING COMPANY (US) INC.,USA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAXATION 2(1)(1), DELHI, DELHI

In the result, appeal of the assessee is partly allowed in the terms aforesaid

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.846/िद"ी/2025(िन.व. 2022-23) Inveso Holding Company (Us) Inc., C/O Invesco (India) P. Ltd., 15Th Floor, Block 6, North Tower, Divyasree Orion Sez, Raidurgam, Serilingampally, Hyderabad, Telangana 5000032 ...... अपीलाथ"/Appellant Pan: Aaeci-9027-N बनाम Vs. Assisnat Commissioner Of Income-Tax, International Taxation 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: S/Shri Ankul Goyal & Advitya Grover, Advocates "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 20.12.2024 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2022-23. 2. Shri Ankul Goyal, Appearing On Behalf Of The Assessee Submits That The Solitary Issue In Present Appeal Is Against The Addition Of Rs.54,85,23,539/- In Respect Of Reimbursement Of Cost For Providing It/Support Services Treated As Fee

…आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी "जेश कुमार िसंह, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER आअसं.846/िद"ी/2025(िन.व. 2022-23) Inveso Holding Company (US) Inc., C/o Invesco (india) P. Ltd., 15th Floor, Block 6, North Tower, Divyasree Orion SEZ, Raidurgam, Serilingampally, Hyderabad, Telangana 5000032 ...... अपीलाथ"/Appellant PAN: AAECI-9027-N बनाम Vs. Assisnat Commissioner of Income-Tax, International Taxation 2(1)(1), Civic Centre, ....."ितवादी/Respo…

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…

E SERVICE SINGAPORE PTE LTD.,GURUGRAM vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeals of the assessee in :

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

…as taken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co-ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards intern…

E SERVICE SINGAPORE PTE LTD.,GURUGRAM vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeals of the assessee in :

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

…as taken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co-ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards intern…

HP SERVICES (SINGAPORE) PTE LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeals of the assessee in :

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

…as taken the same view but the first appellate authority had deleted the addition and the revenue did not raise this issue before the Tribunal. A similar view was considered and decided by the co-ordinate bench in the case of Planetcast International Pvt Ltd 152 Taxmann.com 422. The relevant findings read as under: “39. In ground No. 8, the assessee has challenged taxability of receipts from internet bandwidth charges as royalty income. 40. Briefly, the facts are, in course of assessment proceedings, the Assessing Officer noticed that though the assessee had received an amount of Rs.15,66,888/- towards intern…