PRAGATI POWER CORPORATION LTD,NEW DELHI vs. ACIT, CIRCLE 20(1), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

capital assets acquired by the assessee from abroad and therefore, not liable as revenue expenditure u/s 37(1) r/w section 43A of the Act. Pragati Power Corporation vs. ACIT 31.1 In response, vide reply-dated 05.04.2021, assessee submitted that assessee had entered into a contract with BHEL on turnkey basis for in-house development of a power plant at Bawana

COMMISSIONER OF INCOME TAX

capital reduced correspondingly. This result is certainly not intended.” 2012:DHC:4393-DB ITA No. 444/2011 Page 25 of 30 30. While dealing with the detailed arguments raised by the Revenue, the Division Bench of this Court observed that broadly speaking the figure of total income is arrived at, as per the Act, in four stages. Firstly, the income

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

capital gain of Rs.1,55,67,260 that was already subject to tax in the state of residence, i.e. Singapore and duly allowed by DRP vide order 30.03.2025. Interest Income Interest from Sugam from of 31.03.2016 3 166 investment NCDs Evidenced from Rs.53,76,00,000/ 26AS - Interest from ICC Realty Pvt Ltd Interest Income 166 & from investment NCDs evidenced

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

capital gain of Rs.1,55,67,260 that was already subject to tax in the state of residence, i.e. Singapore and duly allowed by DRP vide order 30.03.2025. Interest Income Interest from Sugam from of 31.03.2016 3 166 investment NCDs Evidenced from Rs.53,76,00,000/ 26AS - Interest from ICC Realty Pvt Ltd Interest Income 166 & from investment NCDs evidenced

HOME CREDIT INTERNATIONAL A.S.,CZECH REPUBLIC vs. ASSISTANT. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, appeal is partly allowed, as indicated above

Bench: Shri Saktijit Dey, Vice- & Shri Pradip Kumar Kediaassessment Year: 2020-21

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; ………. (iva) the use or right to use any industrial, commercial or scientific equipment but not including the amounts referred to in section 4413B

ARES DIVERSIFIED,NEW DELHI vs. ACIT CENTRAL INTL. TAXATION 1(1)(1), NEW DELHI

The appeals are allowed

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharma

capital gains by rejecting benefit of DTAA by holding that assessee was into treaty shopping and there was fiscal evasion. 2.3 The DRP, examined the objections of assessee and observed as follows; “4. DRP's Directions: The Panel has carefully considered the paperbook attached with Form 35A filed on 28.10.2022, the AO's draft order dated

ARES DIVERSIFIED,NEW DELHI vs. ACIT CENTRAL INTL. TAXATION 1(1)(1), NEW DELHI

The appeals are allowed

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharma

capital gains by rejecting benefit of DTAA by holding that assessee was into treaty shopping and there was fiscal evasion. 2.3 The DRP, examined the objections of assessee and observed as follows; “4. DRP's Directions: The Panel has carefully considered the paperbook attached with Form 35A filed on 28.10.2022, the AO's draft order dated

HCL (BRAZIL) TECHNOLOGIES DA INFORMACAO EIRELI,NEW DELHI vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES MAYLASIA SDN BHD,MALAYSIA vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES BV,NETHERLANDS vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES BELGIUM BVBA,NEW DELHI vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES ITALY S.P.A,ITALY vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES DENMARK APS,NEW DELHI vs. ACIT CIRCLE- 2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL SINGAPORE PTE LTD,NEW DELHI vs. ACIT CIRCLE INTERNATIONAL TAXATION 2(1)(1), NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES PHILIPPINES INC.,NEW DELHI vs. ACIT,CIRCLE-INT. TAX 2(1)(1), NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL TECHNOLOGIES FRANCE,NEW DELHI vs. ACIT,CIRCLE-INT. TAX 2(1)(1), NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL POLAND SP ZOO,POLAND vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income

HCL CANADA INC.,CANADA vs. ACIT CIRCLE -2(1)(1) INTERNATIONAL TAXATION, NEW DELHI

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

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

gains, from whatever source derived, which falls within the categories set out there. And so on. The first authoritative judicial pronouncement appears in Rhodesia Metals Ltd. (Liquidator)v. Commissioner of Taxes [1941] 9 ITR (Suppl.) 45, 52 (PC), where the Privy Council approved of the passage quoted by Mr. Justice de Villiers from Mr. Ingram's work on income