SHENHZHEN SDG INFORMATION CO. LTD.,DELHI vs. CIRCLE INT. TAXATION 3(1)(2), DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Commissioner Of Income Tax, Shenhzhen Sdg Information Co. Ltd., International Taxation-3, C/O- Tass Advisors Llp, 62, New Delhi Lower Ground Floor, Pocket 2, Jasola, New Delhi Pan: Aavcs7426C (Appellant) (Respondent) Assessee By Sh. Divyanshu Agrawal, Adv. Sh. Anubhav Rastogi, Adv. Department By Sh. Vijay B Vasanta, Cit(Dr) Date Of Hearing 10.03.2025 Date Of Pronouncement 05.06.2025 Order

gains, both the contracting states have right to tax such income. However, in respect of active income (business income), the source country has a right to tax only when the non-resident has a PE in that state. The threshold of PE under DTAAs and "business connection" under Income-tax Act cover situations where the business activities of non- resident

PACIFIC CREST PTE LTD,NOIDA vs. DCIT CIRCLE-2(2)(2) INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2012-13

44B, the following section shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April 1983, namely: — Special provision for computing, profits and gains in connection with the business of exploration, etc., of mineral oils. '44BB (1) Notwithstanding .anything to the contrary contained in sections 28 to 41 and sections

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

capital of RJA Corporation was two million and two hundred fifty thousand Jordanian Dinars was to be paid out of the State’s treasury. The Council of Ministers of Jordan would have the right to terminate the members of the Board of Directors of RJA. The Government of Jordan guaranteed all the obligations of RJA Corporation

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

capital of RJA Corporation was two million and two hundred fifty thousand Jordanian Dinars was to be paid out of the State’s treasury. The Council of Ministers of Jordan would have the right to terminate the members of the Board of Directors of RJA. The Government of Jordan guaranteed all the obligations of RJA Corporation

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

capital of RJA Corporation was two million and two hundred fifty thousand Jordanian Dinars was to be paid out of the State’s treasury. The Council of Ministers of Jordan would have the right to terminate the members of the Board of Directors of RJA. The Government of Jordan guaranteed all the obligations of RJA Corporation

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

capital of RJA Corporation was two million and two hundred fifty thousand Jordanian Dinars was to be paid out of the State’s treasury. The Council of Ministers of Jordan would have the right to terminate the members of the Board of Directors of RJA. The Government of Jordan guaranteed all the obligations of RJA Corporation

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

capital of RJA Corporation was two million and two hundred fifty thousand Jordanian Dinars was to be paid out of the State’s treasury. The Council of Ministers of Jordan would have the right to terminate the members of the Board of Directors of RJA. The Government of Jordan guaranteed all the obligations of RJA Corporation

KREUZ CHALLENGER PTE LTD,SINGAPURE vs. ACIT, INTERNATIONAL TAXATION CIRCLE2(1)(2), NEW DELHI

The appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2019-20 Kreuz Challenger Pte Ltd., Vs Acit, 2, Venture Drive, International Taxation #24-01 Vision Exchange, Circle 2(1)(2), Singapore , 999999 New Delhi. Pan : Aahck3082A

capital asset situated in India (referred as business income). Explanation 1(a) to Section 9(1)(i) of the Act provides an exclusion in the case of operations which are not carried out in India. The explanation provides that the income of the business deemed under this clause to accrue or arise in India shall be only that part