ADIT INTL. TAXATION, DEHRADUN vs. M/S. HAMPSON RUSSELL LTD. PARTNERSHIP., MUMBAI

In the result, the appeal of the Revenue is allowed partly for statistical purposes

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

House Coopers Pvt. Ltd., Plot No. 18-A, Station Road, Bandra (West) Mumbai. PAN : AADFH8957J (Appellant) (Respondent) And Assessment Year: 2007-08 M/s. Hampson Russell Ltd. Vs. ADIT, International Taxation, Partnership, 510 715-5 Avenue, Dehradun S.W. Calgry Alberta, Canada PAN : AADFH8957J (Appellant) (Respondent) Department by Sh. Amrit Lal, Sr.DR Assessee by S/sh. Ravi Sharma & Rishabh Malhotra, Advocates Date

DIRECTOR OF INCOME TAX vs. INFRASOFT LTD

Section 14(a)(i) of the Copyright Act which permits the copyright holder to reproduce the work in any material form including the storing of it in any medium by electronic means. We may also notice Section 52(1)(aa) of the Copyright Act which lists out certain acts which cannot be considered as infringement of copyright. The particular clause

ONGC AS REPRESENTATIVE ASSESSEE OF DEWEY & LEBOEUF INTERNATIONAL COMPANY LLC, USA,DEHRADUN vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

Bench: Shri R. K. Panda & Ms Suchitra Kambleongc As Representative Assessee Vs Dcit (International Of Dewey & Leboeuf International Taxation) Company Llc, Usa Circle-Ii Dgm-Head, Oil & Natural Gas Dehradun Corporation Ltd. Room No. 244, Old Secretariat, Tel Bhawan (Respondent) Dehradun Aaaco1598A (Appellant) Ongc As Representative Assessee Vs Dcit (International Of University Of New South Wales, Taxation) Australia Circle-Ii Dgm-Head, Oil & Natural Gas Dehradun Corporation Ltd. Room No. 244, Old Secretariat, Tel Bhawan (Respondent) Dehradun Aaaco1598A (Appellant)

house R&D facility of ONGC viz., Institute of Reservoir Studies (‘IRS’), Ahmedabad, which was primarily engaged in carrying out R&D work related to enhancement of recovery of oil/hydrocarbons through improved/enhanced recovery studies. The services covered under the said contract are as under:- • Supply of hardware (High Resolution CT Scanner) including commissioning and testing; • Supply of software including installation

ADIT INTL. TAXATION, DEHRADUN vs. HRS SEISMIC SERVICES LTD.,, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Smt Diva Singh & Sh.Inturi Rama Rao

House Coper Dehradun-248001. Pvt.Ltd., Plot No.-18A, Nanak Road, (APPELLANT) Bandra (west), Mumbai-400050 (RESPONDENT) Appellant by Sh.A.K.Siroha, CIT DR Respondent by Sh.Ravi Sharma, Adv. Date of Hearing 20.08.2015 Date of Pronouncement 30.09.2015 ORDER This is an appeal filed by the Revenue assailing the correctness of the order dated 16.11.2011 of CIT(A)-II, Dehradun pertaining

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

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.

115A of the Act. Therefore, we direct the AO/TPO to delete the adjustment or attributions applied. In the result, grounds raised in this regard are allowed. 52. With regard to Ground No.7 regarding penalty proceedings under section 271AA of the Act, ld. AR submitted that in the transfer pricing order dated 08.06.2023 passed under section 92CA

GE PRECISION HEALTHCARE LLC,KARNATAKA vs. ACIT CIRCLE INTERNATIONAL TAX 1(3)(1), NEW DELHI

In the result, appeal is allowed, as indicated above

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2020-21

115A of the Act. The assessee also received an amount of Rs.10,66,35,790/- towards software licence fee cross charged to its affiliates in India, namely, Wipro GE Healthcare Pvt. Ltd., GE 2 | P a g e AY: 2020-21 BE Pvt. Ltd. and GE India Industrial Pvt. Ltd. However, the software licence fee received as reimbursement from

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

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

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

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

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

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

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

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

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

JDIT, NEW DELHI vs. M/S. VOITH SIEMENS HYDRO KRAFTWERSKETECHNIK GMBH & CO., KG, NEW DELHI

In the result the appeal of the revenue is dismissed

Bench: Shri I.C.Sudhir & Shri Prashant Maharishi

House at Orissa. This contract was entered into vide 4th March 2002 and according to that contractor was required to supply material and rendered supervision services & training services. The appellant filed its return of income offering 10% of total amount of supply of material and equipment of Rs. 2,37,55,936/- i.e. Rs.23,75,590/- u/s 44BBB

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 3(1)(1) INTERNATIONAL TAXATION, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra[A.Y 2017-18]

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 20.08.2024 Date

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), CIVIC CENTRE, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 21.08.2024 Date

QUALCOMM INCORPORATED,SAN DIEGO, CALIFORNIA vs. DCIT CIRCLE 3(1)(1) INTERNATIONAL TAXATION, CIVIC CENTRE, NEW DELHI

In the result, all the captioned appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

House Drive International Taxation San Diego, California, New Delhi The Skyview 10, 18’ F Survey No. 83, 1 Raidurg, Hyderabad, Telangana PAN: AAACQ 1484 H (Applicant) (Respondent) Assessee By : Shri Nishant Thakakr, Adv Ms. Jasmin Amalsadvala, Adv Shri Naveen K. Agarwal, CA Shri Zoheb Bhalwani, CA Department By : Shri Vijay B. Vasanta, CIT-DR Date of Hearing : 21.08.2024 Date

AIRPORT AUTHORITY OF INDIA,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are allowed

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5162/Del/2012 : Asstt. Year : 2010-11 Ita No. 5163/Del/2012 : Asstt. Year : 2011-12 Airports Authority Of India, Vs Income Tax Officer(Tds), Rajiv Gandhi Bhavan, Safdarjung Ward-1(1), Airport, New Delhi-110003 New Delhi (Appellant) (Respondent) Pan No. Aaaca6412D Assessee By : Sh. Ashish Gupta, Adv. Revenue By : Sh. Sohail Malik, Sr. Dr Date Of Hearing: 24.02.2021 Date Of Pronouncement: 04.05.2021

115A of the Income Tax Act, 1961. The reasoning given by the AO is as under:  The contention of the applicant that FAA is a sovereign entity and entitled to immunity from taxation under the Act is not well founded in law and facts.  Sovereign immunity can only be claimed in respect of the acts done in its sovereign capacity

AIRPORT AUTHORITY OF INDIA,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are allowed

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5162/Del/2012 : Asstt. Year : 2010-11 Ita No. 5163/Del/2012 : Asstt. Year : 2011-12 Airports Authority Of India, Vs Income Tax Officer(Tds), Rajiv Gandhi Bhavan, Safdarjung Ward-1(1), Airport, New Delhi-110003 New Delhi (Appellant) (Respondent) Pan No. Aaaca6412D Assessee By : Sh. Ashish Gupta, Adv. Revenue By : Sh. Sohail Malik, Sr. Dr Date Of Hearing: 24.02.2021 Date Of Pronouncement: 04.05.2021

115A of the Income Tax Act, 1961. The reasoning given by the AO is as under:  The contention of the applicant that FAA is a sovereign entity and entitled to immunity from taxation under the Act is not well founded in law and facts.  Sovereign immunity can only be claimed in respect of the acts done in its sovereign capacity

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit