SFDC Ireland Ltd. v. CIT

465 ITR 471Reported decision2024#25072 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 348,615 Indian tax judgments — from 2025 to 2025.

Judgments citing SFDC Ireland Ltd. v. CIT

Acronis Asia Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )Range-1(1)(1), Mumbai

In the result, the appeal filed by the assessee is

ITA 2035/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Dec 2025AY 2022-23
Section 10(50)Section 143(3)Section 144C(13)

…irrelevant for characterising the nature of income in the hands of the distributor. This principle has been clearly enunciated by judicial authorities and has been reiterated by the Hon'ble Delhi High Court in the case of SFDC Ireland Ltd. v. CIT reported in 465 ITR 471. The relevant observations of the Hon'ble High Court, which directly address the distinction between services rendered to a distributor and benefits accruing to end customers, are reproduced hereunder. "6. SFDC India in terms of the Reseller Agreement was to market, distribute and sell SFDC products in India. However, it was accorded no rights ov…

Tungsten Automation England Limited (Formerly Known As Tungsten Network Limited) vs. Deputy Commissioner of Income Tax, International Taxation, Circle 3(1)(1), New Delhi

ITA/93/2025HC Delhi14 Jul 2025

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

For Appellant: Mr Deepak Chopra and Ms Priya TandonFor Respondent: Mr Sunil Agarwal, SSC with Mr Shivansh B
Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 148ASection 260A

…r12, this Court had considered a similar contention with regard to the training imparted to the Indian entity in connection with the sale of certain products referred to in the relevant agreement and the said decision as 11 (2014) 364 ITR 336. 12 (2024) 465 ITR 471. Digitally Signed By:GANGA SINGH RAWAT Signing Date:14.07.2025 18:41:49 Signature Not Verified ITA 92/2025 and ITA 93/2025 Page 47 of 49 ‘SFDC products’. This Court had rejected that the training imparted in the context of the said p…

Tungsten Automation England Limited (Formerly Known As Tungsten Network Limited) vs. Deputy Commissioner of Income Tax, International Taxation, Circle 3(1)(1) New Delhi

ITA/92/2025HC Delhi14 Jul 2025

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

For Appellant: Mr Deepak Chopra and Ms Priya TandonFor Respondent: Mr Sunil Agarwal, SSC with Mr Shivansh B
Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 148ASection 260A

…r12, this Court had considered a similar contention with regard to the training imparted to the Indian entity in connection with the sale of certain products referred to in the relevant agreement and the said decision as 11 (2014) 364 ITR 336. 12 (2024) 465 ITR 471. Digitally Signed By:GANGA SINGH RAWAT Signing Date:14.07.2025 18:41:49 Signature Not Verified ITA 92/2025 and ITA 93/2025 Page 47 of 49 ‘SFDC products’. This Court had rejected that the training imparted in the context of the said p…

SFDC Ireland Ltd. v. CIT (465 ITR 471) — Cited in 3 Judgments | BharatTax