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Chapter-heads v

List of Cases Digested

List of Cases Affirmed/Reversed/Overruled/Approved/ Disapproved

List of Cases against which SLP Dismissed/Granted/ Notice issued by Supreme Court

List of Circulars & Notifications Judicially Analysed by Supreme Court/High Courts

SECTION 2

Charge of income-tax

SECTIONS 10 TO 10C

Income received from units [Section 10(35)] 113-114

Compensation received on compulsory acquisition of Rural Agricultural Land [Section 10(37)] 115

Transfer of certain long-term securities [Section 10(38)] 116-123

Certain body, authority, board, etc., constituted for benefit of general public [Section 10(46)] 124

Newly established undertakings in free trade zone, etc. [Section 10A] 125-130

Newly established units in special economic zones [Section 10AA] 131-132

Newly established 100% export-oriented undertakings [Section 10B] 133-138

SECTIONS 11 TO 13

purpose [Section 2( 15 )]

of income from property held under charitable/ religious trust [Section 11]

for applicability of sections 11 and 12 [Section 12A]

for registration [Sections 12AA & 12AB]

[Section 13]

SECTION 13A

SECTIONS 15 TO 17

SECTIONS 22 TO 27

SECTIONS 28 & 29

SECTION

Special

& doubtful debts [Section 36(1)(viia)]

applicability of section 36(1)(vii) & 36(1)(viia)

SECTION 36(1)(viii)

SECTIONS 40, 40A & 43B

SECTIONS 45 TO 55A

SECTIONS 56 TO 59

SECTION 69 SECTION 69A

SECTION 69B

SECTION 69C

SECTIONS 70 TO 80

SECTIONS 80A TO 89A

SECTION 90

of Double Taxation [Article 23 of OECD Model Convention]

Agreement Procedure (MAP) [Article 25 of OECD Model Convention]

SECTIONS 92 TO 92F & 144C

SECTIONS 95 TO 102

SECTION 115BBE

SECTIONS 115J TO 115JB

SECTIONS 119, 124 & 127

SECTIONS 131 TO 138

SECTION 139AA

SECTION 142 SECTIONS 143 & 144

SECTION 144B

SECTIONS 145 & 145A

SECTIONS 147 TO 153

Procedure before issuance of notice u/s 148 [Section 148A] 1150-1184

Time limit for notices u/ss 148 & 148A [Section 149] 1185-1237

Assessment is in pursuance of an order on appeal, etc. [Section 150] 1238-1239

Exception to section 150(1) 1240

Sanction for issue of notice [Section 151] 1241-1262

Faceless reassessment [Section 151A] 1263-1286

Time limit for completion of assessment, reassessment and recomputation [Section 153] 1287-1295

SECTIONS 153A TO 153D

Assessment of Search or Requisition cases

General 1296-1297

Assessment in case of search or requisition [Section 153A] 1298-1303

Time limit for completion of assessment [Section 153B] 1304-1305

Assessment of income of any other person [Section 153C] 1306-1332

Prior approval necessary for assessment [Section 153D] 1333 SECTION 154

SECTIONS 158B TO 158BI

[Section 158BC] 1342-1344 Undisclosed income of any other person [Section 158BD] 1345 Time limit for completion of block assessment [Section 158BE] 1346

SECTIONS 159 TO 179

Liability in special cases Legal representatives [Section 159] 1347

Charge of tax where share of beneficiaries unknown [Section 164] 1348-1349

of directors of private company [Section 179] 1350

SECTIONS 184 TO 189A

Special provisions applicable to firms

Joint and several liability of partners for tax payable by firm [Section 188A] 1351

SECTIONS 190 TO 206C & 234E

Deduction/Collection of tax at source (TDS/TCS)

[Section 194A]

[Section 194-I]

on acquisition of certain immovable property [Section 194LA]

[Section 195]

[Section 197]

[Section 234E]

SECTIONS 220 TO 226

Collection and recovery of tax

When tax payable and when assessee deemed in default [Section 220] 1396-1428

to TRO [Section 222] 1429-1432

[Section 226] 1433

CASE NOS.

SECTIONS 234A TO 234C

Interest, chargeable as

Defaults in furnishing return of income [Section 234A] 1434

Defaults in payment of advance tax [Section 234B] 1435-1436

Refunds

SECTIONS 237 TO 245

Refunds [Section 237] 1437-1449

Form of claim for refund and limitation [Section 239] 1450-1451

Withholding of refund [Section 241A] 1452

Interest on refunds [Section 244A] 1453-1462

Set off and withholding of refunds [Section 245] 1463-1470

SECTIONS 245A TO 245M

Settlement Commission

Application for settlement of cases [Section 245C] 1471-1477

Procedure on receipt of an application under section 245C [Section 245D] 1478-1482

Powers and Procedure [Section 245F] 1483

Power to grant immunity from prosecution and penalty [Section 245H] 1484-1486

SECTION 245MA

Dispute Resolution Committee (DRC)

Opportunity of hearing 1487

SECTIONS 246 TO 251

Commissioner (Appeals) & Joint Commissioner (Appeals)

Appealable orders before Commissioner (Appeals) [Section 246A] 1488-1492

Form of appeal and limitation [Section 249] 1493-1494

Procedure in appeal [Section 250] 1495-1504

Others 1505

SECTIONS 252 TO 255

Appellate Tribunal Appeals [Section 253] 1506-1514

CASE NOS.

Orders [Section 254] 1515-1520

Procedure [Section 255] 1521-1525

Appeals to High Court

SECTIONS 260A & 260B

Territorial jurisdiction 1526

Substantial question of law 1527-1530

Condonation of delay [Section 260A(2A)] 1531-1532

Opportunity of being heard 1533

Code of Civil Procedure, 1908, applicability of [Section 260A(7)] 1534

Power to Review/Recall 1535-1536

Remarks on Members of Tribunal 1537

SECTIONS

261 & 262

Appeals to Supreme Court

Dispute Settled under Vivad se Vishwas Scheme 1538

SECTIONS 263 & 264

Revision of orders

Revision of orders prejudicial to revenue [Section 263] 1539-1545

Revision of other orders [Section 264] 1546-1553

SECTION 268A

Filing of appeal by income-tax authority

Circular No. 3/2018, dated 11-7-2018 1554-1555

Circular Nos. 5/2024 & 9/2024, dated 15-3-2024 & 17-9-2024 1556-1563

SECTION 269ST

Mode of undertaking transactions

Scope of provision 1564

Apex Court guidelines for strict implementation of provision 1565

SECTIONS 269U TO 269UP

Purchase by Central Government of immovable properties in certain cases of transfer

Final and conclusive order of appropriate authority [Section 269UN] 1566

CASE NOS.

SECTIONS 270A TO 275

Penalties imposable

Under-reporting and misreporting of income [Section 270A] 1567-1569

Concealment of income [Section 271(1)(c)] 1570-1592

Failure to keep and maintain information and document, etc., in respect of certain transactions [Section 271AA] 1593

Search cases [Section 271AAA] 1594-1596

Failure to get accounts audited [Section 271B] 1597

Failure to deduct TDS [Section 271C] 1598-1601

Failure to comply with provisions of section 269SS [Section 271D] 1602-1605

Failure to comply with provisions of section 269ST [Section 271DA] 1606

Failure to comply with provisions of section 269T [Section 271E] 1607-1608

Failure to furnish information or document under section 92D [Section 271G] 1609

Power to grant immunity from penalty [Section 273AA] 1610

SECTIONS 275A TO 279A

Offences & Prosecution

Failure to pay tax to credit of Central Government under Chapter XII-D or XVII-B [Section 276B] 1611-1616

Wilful attempt to evade tax, etc. [Section 276C] 1617-1626

Failure to furnish return of income [Section 276CC] 1627-1629

Punishment not to be imposed in certain cases [Section 278AA] 1630-1631

Offences by companies [Section 278B] 1632-1633

Presumption as to culpable mental state [Section 278E] 1634

Prosecution to be at instance of Chief Commissioner [Section 279] 1635-1642

SECTION 281

Certain transfers to be void

Valid transfer 1643-1644

SECTION 281B

Provisional attachment to protect revenue in certain cases

Attachable property 1645

Time-limit for provisional attachment order 1646-1647

Release of attached property 1648

SECTION 282 Service of notice generally

SECTION 292BB Notice deemed to be valid in certain circumstances

SECTION 293

of suits in civil courts Suit 1652

OTHER ACTS /RULES/SCHEMES

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 1653-1654

Chartered Accountants Act, 1949 1655-1657

Direct Tax Dispute Resolution Scheme, 2016 1658

Direct Tax Vivad se Vishwas Act, 2020 1659-1676

Direct Tax Vivad se Vishwas Scheme, 2024 1677-1684 Expenditure-Tax Act, 1987 1685-1686 Gift Tax Act, 1958 1687 Income Declaration Scheme, 2016 1688-1689

Indian Revenue Service Rules, 2015 1690

Interest-Tax Act, 1974 1691-1692

Prohibition of Benami Property Transactions Act, 1988 1693-1695

Specified Bank Notes (Cessation of Liabilities) Act, 2017 1696

Wealth-tax Act, 1957 1697

WORDS AND PHRASES

Income-Tax Act, 1961 1698-1715

Direct Tax Vivad se Vishwas Act, 2020 1716 Prohibition of Benami Property Transactions Act, 1988 1717 PAGE NO. SUBJECT INDEX 1121

Chapter-heads

List of Cases Digested

List of Circulars & Notifications Judicially Analysed by Tribunal I-115-I-128

SECTION 2

SECTION 4

SECTION 9

Income deemed to accrue or arise in India

Permanent

[Article 5 of OECD Model Convention]

SECTIONS 10 TO 10C

Educational institutions [Section 10(23C)(iiiab)/(iiiad)/(vi)]

Hospitals [Section 10(23C)(iiiac)/(iiiae)/(via)]

Approved charitable fund/institution or approved public religious/ charitable trust [Section 10(23C)(iv)/(v)] 342-344

Investment income of VCC/VCF in VCU [Section 10(23FB)]

Certain incomes of infrastructure capital fund/company [Section 10(23G)]

individual [Section 10(26AAA)]

Agricultural produce market committee/board [Section 10(26AAB)]

back of shares [Section 10(34A)]

Income received from units [Section 10(35)]

Compensation received on compulsory acquisition of agricultural land [Section 10(37)]

of certain long-term securities [Section 10(38)]

SECTIONS 11

TO 13

trusts

purpose [Section 2(15)]

of income from property held under charitable/ religious trust [Section 11] 417-504 Conditions for applicability of sections 11 and 12 [Section 12A] 505-532 Procedure for registration [Sections 12A(1)(ac), 12AA & 12AB] 533-623

of exemption [Section 13] 624-637

SECTION 14A

Expenditure incurred in relation to income not includible in total income

of expenditure 682-715

SECTIONS 15 TO 17

SECTIONS 22 TO 27

SECTIONS 28 & 29

SECTION 35DDA

SECTION 35E

SECTION 36(1)(vii), (viia) & 36(2)

Bad debts and provision for bad & doubtful debts

Bad debts [Section 36(1)(vii) & 36(2)] 992-1005

Provision for bad & doubtful debts [Section 36(1)(viia)] 1006-1019

Simultaneous applicability of section 36(1)(vii) & 36(1)(viia) 1020-1022

SECTION 36(1)(viii)

Special reserve created and maintained by specified entities

finance

This provision vis-à-vis section 36(1)(viia)

SECTION 37(1)

Business expenditure

Allowability 1030-1267 Year in which deductible 1268-1274

SECTIONS 40, 40A & 43B

Business disallowance

Interest, etc., paid to non-residents without deducting TDS [Section 40(a)(i)] 1275-1279

Interest, etc., paid to residents without deducting TDS [Section 40(a)(ia)] 1280-1303

Rates or taxes [Section 40(a)(ii)] 1304-1305

Fees/charges levied exclusively on or any appropriations from State Government undertaking by State Government [Section 40(a)(iib)] 1306

Interest, salary, etc., paid by firm to partner [Section 40(b)] 1307-1308

Excessive/Unreasonable expenditure [Section 40A(2)] 1309-1318

Cash payment exceeding prescribed limit [Section 40A(3), (3A) & (4)] 1319-1328

Gratuity provision [Section 40A(7)] 1329-1330

Employer’s Contribution for employee’s benefit to funds, trust, etc. [Section 40A(9)] 1331

Certain deductions to be only on actual payment [Section 43B] 1332-1359 CASE NOS.

SECTION 41

Profits chargeable to tax

Remission/Cessation of trading liability [Sub-section (1)] 1360-1375

Withdrawal from special reserve [Sub-section (4A)] 1376

SECTION 43

Definitions of certain terms relevant to income from profits and gains of business or profession

[Clause (1)]

transaction [Clause (5)]

SECTION 43A

SECTION 43CA

Special provision for full value of consideration for transfer of assets other than capital assets in certain cases

SECTION 43CB

SECTION

SECTIONS 45 TO 55A

Capital gains Capital asset [Section 2(14)] 1423-1436

[Section 2(47)] 1437-1443

gains, chargeable as [Section 45] 1447-1467

as transfer [Section 47] 1472-1475

Computation of capital gains [Sections 48, 49 & 55] 1476-1513

Special provision for computation of capital gains in case of depreciable assets [Section 50] 1514-1522

Computation of capital gains in case of slump sale [Section 50B] 1523

Special provision for computation of full value of consideration [Section 50C] 1524-1549

1550-1619

SECTIONS 56 TO 59

Income from other sources

from other sources, chargeable as [Section 56] 1620-1695

[Section 57] 1696-1710 SECTION 68

SECTION 69 SECTION 69A

SECTION 69B

Unexplained expenditure

SECTION 69C

Bogus purchases, examination/verification of 1926

Opportunity of being heard 1927

Non-consideration of assessee’s reply 1928-1929

Non-compliance of section 133 notice 1930-1931

Illustrations 1932-1953

Taxable on whom 1954

Quantum of addition 1955-1964

SECTIONS 70 TO 80

Set off, or Carry forward and set off, of Losses

Set off of losses under same head of income [Section 70] 1965-1971

Set off of losses under any other head of income [Section 71] 1972-1973

Business losses [Section 72] 1974-1976

Accumulated loss and unabsorbed depreciation allowance in amalgamation or demerger, etc. [Section 72A] 1977-1978

Accumulated loss and unabsorbed depreciation allowance in business reorganisation of co-operative banks [Section 72AB] 1979

Losses under head “capital gains” [Section 74] 1980-1981

Submission of return for losses [Section 80] 1982-1984

SECTIONS 80A TO 89A

Deductions, Rebates & Reliefs

Deductions to be made in computing total income [Section 80A] 1985-1987

Deduction not to be allowed unless return furnished [Section 80AC] 1988

Deduction in respect of life insurance premia, etc. [Section 80C] 1989-1990

Donation to certain charitable institutions, etc. [Section 80G] 1991-2048

Political contributions by companies [Section 80GGB] 2049

Political contributions by other persons [Section 80GGC] 2050

Profits retained for export business [Section 80HHC] 2051-2056

Profits and gains from industrial undertakings or enterprises engaged in infrastructure development, etc. [Section 80-IA] 2057-2068

Profits and gains by an undertaking or enterprise engaged in Development of SEZ [Section 80-IAB] 2069

Profits and gains from industrial undertakings other than Infrastructure development undertakings [Section 80-IB] 2070-2073

Certain undertakings/enterprises in certain special category states [Section 80-IC] 2074-2087

Certain undertakings in north-eastern states [Section 80-IE] 2088

Employment of new employees [Section 80JJAA] 2089-2091

Inter-Corporate dividends [Section 80M] 2092

Income of co-operative societies [Section 80P] 2093-2111

Rebate of income-tax in case of certain individuals [Section 87A] 2112

Relief available when salary is paid in arrears or in advance [Section 89] 2113-2114

Relief from taxation in income from retirement benefit account maintained in a notified country [Section 89A] 2115

SECTION 90

Double taxation relief where Agreement exists

Overriding effect of DTAA [Section 90(2)] 2116 Taxes covered [Article 2 of OECD Model Convention] 2117

Elimination of double

[Article 23 of

vention] 2118-2136

SECTIONS 92 TO 92F & 144C

enterprise [Section 92A] 2142-2144

transaction [Section 92B] 2145-2176 Specified domestic transaction [Section 92BA] 2177-2185

Arm’s length price, computation of [Section 92C] 2186-2535

Reference to TPO [Section 92CA] 2536-2543

Advance pricing agreements [Sections 92CC & 92CD] 2544-2551

Accountant’s report [Section 92E] 2552

Reference to dispute resolution panel [Section 144C] 2553-2573

SECTION 94B

Limitation on interest deduction in certain cases

Fresh claim of deduction before appellate authority 2574 CASE NOS.

SECTION 112

SECTION 115A Tax on dividends, royalty and technical service fees in case of foreign companies

in shares of Indian subsidiary

SECTION 115BAA

SECTION 115BAC

SECTION 115BBC

SECTION 115BBE

SECTION 115-O

SECTIONS 115QA TO 115QC

Tax on distributed income of domestic company for buy-back of

SECTION 115U

SECTIONS 115V TO 115VZC

SECTIONS 120, 124 & 127

SECTIONS 131 TO 138

Inquiry before assessment

SECTION 142

Special audit 2647

SECTIONS 143 & 144

Assessment

Summary assessment [Section 143(1)] 2648-2657

Scrutiny assessment [Section 143(2) & (3)] 2658-2683

Best judgment assessment [Section 144] 2684-2686

SECTION 144B

Faceless assessment

Method of accounting

General [Section 145]

SECTIONS 145 & 145A

2688-2725

Valuation of inventory [Section 145A] 2726-2732

SECTIONS 147 TO 153

Reassessment Income escaping assessment [Section 147] 2733-2747 Notice for reassessment [Section 148] 2748-2758

Procedure before issuance of notice u/s 148 [Section 148A] 2759-2762

Prior approval for assessment, reassessment or recomputation in certain cases [Section 148B] 2763

Time limit for notices u/ss 148 & 148A [Section 149] 2764-2781

Sanction for issue of notice [Section 151] 2782-2804

Faceless reassessment [Section 151A] 2805-2806

Time Limit for completion of assessment, reassessment and recomputation [Section 153] 2807-2808

SECTIONS 153A TO 153D

Assessment of search or requisition cases

General 2809

Assessment in case of search or requisition [Section 153A] 2810-2822

Time limit for completion of assessment [Section 153B] 2823-2825

CASE NOS.

Assessment of income of any other person [Section 153C] 2826-2830

Prior approval necessary for assessment [Section 153D] 2831-2844

Rectification of mistake

SECTION 154

Reasonable opportunity of being heard [Sub-section (3)] 2845-2846

Illustrations 2847-2849

Time-Limit for making rectification order [Sub-section (8)] 2850

SECTION 156A

Modification and revision of notice in certain cases

Resolution plan not finalised 2851-2852

SECTIONS 158BC & 158BD

SECTIONS 159 TO 179

Liability in special cases

Legal representatives [Section 159] 2854

Charge of tax where share of beneficiaries unknown [Section 164] 2855-2863

Charge of tax where shares of member in AOPs or BOIs unknown, etc. [Section 167B] 2864-2865

Executors [Section 168] 2866

SECTIONS 190 TO 206C

Deduction/Collection of Tax at Source (TDS/TCS)

Salary [Section 192] 2867

Interest other than interest on securities [Section 194A] 2868-2877

Contractors, payment to [Section 194C] 2878-2889

Insurance commission [Section 194D] 2890

Commission or brokerage [Section 194H] 2891-2900

Rent [Section 194-I] 2901-2904

Transfer of certain immovable property other than agricultural land [Section 194-IA] 2905-2907

Joint development agreement [Section 194-IC] 2908-2909

Fees for professional/technical services [Section 194J] 2910-2917

Interest on certain bonds and government securities [Section 194LD] 2918

Payment by E-Commerce operator to E-Commerce participant [Section 194-O] 2919

Purchase of goods [Section 194Q] 2920

Non-residents [Section 195] 2921-2933

Certificate for deduction at lower/nil rate [Section 197] 2934

Credit for tax deducted [Section 199] 2935-2955

Processing of statements of TDS & other statements [Section 200A] 2956

Consequences of failure to deduct/pay tax [Section 201] 2957-2965

Requirement to furnish PAN [Section 206AA] 2966 Collection of tax at source [Section 206C] 2967-2968

SECTIONS 207 TO 219

2969

for advance tax [Section 219] 2970

SECTION 226

When tax payable when assessee deemed in default

Interest [Sub-section (2)] 2971-2972

Stay of Demand [Sub-section (6)] 2973

SECTIONS

234A TO 234C

Interest, chargeable as

Defaults in furnishing return of income [Section 234A] 2974

Defaults in payment of advance tax [Section 234B] 2975-2979

Deferment of advance tax [Section 234C] 2980-2984

SECTIONS

237 TO 245 Refunds Refunds [Section 237] 2985 Interest on refunds [Section 244A] 2986-2990

SECTIONS 246 TO 251

Commissioner (Appeals) & Joint Commissioner (Appeals)

Appealable orders before Commissioner (Appeals) [Section 246A] 2991

CASE NOS.

Form of appeal and limitation [Section 249] 2992-2999

Procedure in appeal [Section 250] 3000-3004

Powers [Section 251] 3005-3015

Appellate Tribunal

SECTIONS 252 TO 255

Appeals [Section 253] 3016-3023

Orders [Section 254] 3024-3026

Procedure [Section 255] 3027-3029

Revision of orders

SECTIONS 263 & 264

Revision of orders prejudicial to revenue [Section 263] 3030-3037

Revision of other orders [Section 264] 3038

SECTION 268A

Filing of Appeal by Income-Tax Authority

Circular No. 3/2018, dated 11-7-2018 3039

Circular Nos. 5/2024 & 9/2024, dated 15-3-2024 & 17-9-2024 3040-3042

SECTIONS 269SS, 269ST, 269T, 271D, 271DA & 271E

Mode of acceptance, payment or repayment in certain cases to counteract evasion of tax

Mode of taking or accepting certain loans, deposits and specified sum [Section 269SS] 3043-3049

Mode of undertaking Transactions [Section 269SS] 3050

Mode of repayment of certain loans or deposits [Section 269T] 3051-3053

Penalties imposable

SECTIONS 270A TO 275

Under-reporting and misreporting of income [Section 270A] 3054-3063

Concealment of income [Section 271(1)(c)] 3064-3086

Failure to keep, maintain or retain books of account, documents, etc. [Section 271A] 3087

Failure to keep and maintain information and document, etc., in respect of certain transactions [Section 271AA] 3088-3091

Search cases [Section 271AAB] 3092-3096

Unexplained income, etc. [Section 271AAC] 3097

SECTION 9

Income deemed to accrue or arise in India

Extra-territorial income 39

Permanent Establishment (PE) [Article 5 of OECD Model Convention]

Existence of PE in India 40

Fixed place PE

Dependant Agent PE (DAPE) 41-45

Liaison office 46-48

Secondment of employees 49

Strategic oversight services agreement 50

Insurance PE 51

Reassessment 52

Business profits [Article 7 of OECD Model Convention]

Profits attributable to PE, computation of 53

Global net loss 54

Arm’s length transfer 55

Related party transactions 56

Credit card fees 57

Withholding tax rate 58

Absence of PE 59

Dividend [Article 10 of OECD Model Convention]

MFN clause impact 60

Interest [Article 11 of OECD Model Convention]

Notional interest 61

Royalty/fees for technical services [article 12 of OECD Model Convention]

Royalty Advertisement charges 62

Cross-cost charges 63

Inter-connect services 64-65

Satellite transponder services 66-67

Software 68-72

Fees for technical/included services (FTS/FIS)

Access to online content 73

Advisory services 74

Centralised services 75-76

Export commission 77

Logistic support services 78

Management support services 79

Marketing services 80

Reimbursement of expenses

81-82

Repair & maintenance services 83

Secondment of employees 84

Software 85

Testing services 86

Training workshops 87

Royalty or FTS/FIS

Database 88

Software 89

Reassessment 90

Capital gains [Article 13 of OECD Model Convention]

Sale of shares 91

Reassessment 92-94

EXTRA-TERRITORIAL INCOME

39. Income-tax authorities in India do not have jurisdiction to bring to tax income arising from extra-territorial source, that is outside India, in respect of business carried on by foreign companies outside India [Assessment years 2008-09 to 2015-16] [In favour of assessee] [Article 12 of OECD Model Convention]

Vodafone Idea Ltd. v. Dy. DIT, (International Taxation) [2023] 152 taxmann.com 575/457 ITR 189 (Kar.)

Assessee was an ILD license holder and responsible for providing connectivity to calls originating/terminating outside India. It had entered into an agreement with NTOs for international carriage and connectivity services. Assessee had also entered into a capacity transfer agreement with a Belgium entity (Belgacom) which had certain arrangement with Omantel for utilisation of bandwidth. Assessing Officer passed an assessment order holding assessee as ‘defaulter’ for failure to deduct TDS while making payments to the said company. Equipments and submarine cables were situated overseas and Belgacom did not have any ‘permanent establishment’ in India.

Held that the income-tax authorities have no jurisdiction to bring to tax income arising from extra-territorial source. Further, withholding tax liability should not be levied at a higher rate. Since, in the instant case, facilities were situated outside India and agreement was with a Belgium entity which did not have any presence in India, tax authorities in India would have no jurisdiction to bring to tax income arising from extra-territorial source.

Case review : SLP dismissed in Dy. CIT (International Taxation) v. Vodafone Idea Ltd. [2025] 173 taxmann.com 695/304 Taxman 594 (SC); Dy. CIT, International Taxation v. Vodafone Idea Ltd. [2025] 176 taxmann.com 626/306 Taxman 267 (SC)

PERMANENT ESTABLISHMENT (PE) [ARTICLE 5 OF OECD MODEL CONVENTION]

EXISTENCE OF PE IN INDIA

40. Where Commissioner invoked revisionary proceedings on ground that Assessing Officer had not conducted necessary inquiries to verify claim of assessee, a Singapore based company, that it had no PE in India and to verify whether any commercial substance existed in Singapore, since said tentative opinion that assessee was a conduit company formed to obtain tax benefits of India-Singapore DTAA were not put to assessee and assessee was not given any opportunity of hearing, revisionary order was to be set aside [Assessment year 2017-18] [In favour of assessee] [Article 12 of DTAA between India and Singapore]

CIT, International Taxation - 3 v. Zebra Technologies Asia Pacific Pet. Ltd. [2024] 169 taxmann.com 187/[2025] 302 Taxman 380/472 ITR 745 (Delhi)

Assessee, a company incorporated in Singapore, was engaged in the business of wholesale distribution of electronic products as well as services related to after sales, repairs, and technical support services to customers in various parts of world including India. Assessee had received certain amount for rendition of technical support, repair, and maintenance services. Assessee filed its income tax returns for relevant assessment year, inter alia, claiming that it had no PE in India and was not liable to pay tax in respect of aforesaid receipts. Assessing Officer accepted assessee’s claim. Commissioner opined that Assessing Officer had not verified the relevant details to ascertain whether assessee had a PE in India and to ascertain whether any commercial substance existed in Singapore or assessee was merely a conduit company. Accordingly, Commissioner initiated proceeding under section 263 by issuance of a show cause notice. Tribunal set aside the revisionary order on the ground that assessee was not afforded an opportunity to counter allegation. It was noted that Commissioner had faulted Assessing Officer for not undertaking certain enquiries. However, Commissioner had not put the issue regarding treaty shopping to assessee.

Held that there was no fault with the decision of the Tribunal in setting aside the revisionary order passed by the Commissioner.

Case review : Zebra Technologies Asia Pacific Pte. Ltd. v. CIT (International Taxation) [2023] 150 taxmann.com 467/201 ITD 87 (Delhi - Trib.) affirmed

FIXED PLACE PE

Dependant Agent PE (DAPE)

41. Where assessee, a foreign company, had established a liaison office in India which was followed by incorporation of a fully owned subsidiary in India, since revenue had abjectly failed to prove that said subsidiary stood conferred with authority to bind or conclude contracts on behalf of assessee, no DAPE could be said to have come into existence and, thus, assessee could not be said to have a fixed place PE in India [Assessment years 1997-98 and 1998-99] [In favour of assessee] [Article 5 of the DTAA between India and Finland]

CIT, International Taxation v. Nokia Network OY [2025] 171 taxmann. com 757/479

ITR 515 (Delhi)

Assessee, a foreign company, was engaged in manufacture of advanced telecommunication systems and equipment. It had established a liaison office in India in 1994 which was followed by incorporation of a fully owned subsidiary, NIPL, in India. Assessee filed its return of income taking a position that offshore supplies were not exigible to tax. Assessing Officer held that NIPL was liable to be treated as Dependent Agent Permanent Establishment (DAPE). He further held that 70 per cent of total equipment revenue was attributed towards sale of hardware and 30 per cent of the same was attributed towards supply of software and same was taxed as royalty. It was noted that NIPL was pursuing an independent line of business with Indian telecom operators. Revenue had abjectly failed to prove that NIPL stood conferred with authority to bind or conclude contracts on behalf of assessee. NIPL was not generating any revenue or income for the assessee. Onshore activities of NIPL were totally disconnected with supply contracts of assessee. There was, thus, a clear and discernible distinction between the activities undertaken by NIPL and supply contracts executed by assessee.

Held, on facts, that no DAPE could be said to have come into existence and, thus, assessee could not be said to have a fixed place PE in India. Further, income derived from sale of equipment and licensing of software in India could not be taxed in the hands of assessee.

42. Where MIPL was not performing additional function, in absence of material, it could not be taken as dependant agency PE to assessee, a non-resident company [Assessment year 2009-10] [In favour of assessee] [Article 5 of DTAA between India and Japan]

CIT (International Taxation)-2 v. Mitsui and Co. [2025] 170 taxmann. com 827 (Delhi)

Where MIPL was not performing additional function, in the absence

of material, it could not be taken as dependant agency PE to assessee (a non-resident company) liable to tax in India.

Case review : Dy. CIT (International Taxation) v. Mitsui & Co. [2022] 141 taxmann.com 128/94 ITR(T) 34 (Delhi - Trib.) affirmed and SLP dismissed in CIT International Taxation 2 v. Mitsui and Co. [2025] 170 taxmann.com 828/303 Taxman 331 (SC).

43. Where Assessing Officer initiated reassessment proceedings against assessee, a US based company, on ground that assessee had fixed place PE and dependent agent PE in India and was, therefore liable to pay tax in India, since there was no tangible material to establish existence of a PE in India for relevant assessment years, impugned reassessment proceedings were to be quashed [Assessment years 2013-14 to 2016-17] [In favour of the assessee] [Article 5 of DTAA between India and USA]

GE Renewables Grid LLC v. Asstt. CIT [2025] 174 taxmann.com 460 (Delhi)

Assessee, a US-based company, was engaged in development of power grid transmission and distribution management software and engineering services, was issued reassessment notices under section 148 based on survey findings alleging existence of dependent agent PE and fixed place PE in India. It was noted that reasons recorded for reopening did not contain any tangible material to substantiate existence of PE in India for the relevant assessment years.

Held that in the absence of any cogent material to establish existence of PE in India, reassessment proceedings initiated under section 148 were to be quashed.

44. Where Assessing Officer initiated reassessment proceedings against assessee, a foreign company, on ground that assessee had fixed place and dependent agent PE in India and, thus, it was liable to pay tax in India, since reasons as recorded in support of formation of opinion that income had escaped assessment had not alluded to any facts specific to assessment years 2013-14 to 2017-18, impugned reassessment proceedings were to be quashed [Assessment years 2013-14 to 2017-18] [In favour of assessee] [Article 5 of DTAA between India and Finland]

Grid Solutions OY (Ltd.) v. Asstt. CIT, International Taxation [2025] 170 taxmann.com 498/303 Taxman 288/477 ITR 698 (Delhi)

Assessee, a foreign company, was engaged in the business of manufacturing products for efficient power transmission, reactive power compensation and harmonic filtering, as well as related project engineering. Assessee had been awarded a contract by Indian company to supply equipments from outside India. Assessee claimed to have received payment of only 10 per cent advance during the year from

Indian company and, accordingly, had shown nil income. Assessment was completed under section 143(3) accepting income as shown by assessee. Subsequently, a survey under section 133A(2A) was conducted upon GE group which had taken over grid business of assessee in the year 2015. Based on the said survey, impugned reassessment proceedings were initiated against the assessee on the ground that the nature of activities by assessee would establish that assessee had fixed place and dependent agent permanent establishment in India and, thus, it was liable to pay tax in India on income earned from the said contract. It was noted that the Assessing Officer had merely proceeded to adopt and reiterate what was found in the course of survey.

Held that since reasons as recorded in support of formation of opinion that income had escaped assessment had not alluded to any facts specific to assessment years 2013-14 to 2017-18, impugned reassessment proceedings were to be quashed.

45. Where Assessing Officer issued reopening notice against assessee, a foreign company, on ground that a survey conducted on a company revealed that assessee had fixed place and dependent agent PE in India and, thus, it was liable to pay tax in India, since revenue had woefully failed to establish that formation of opinion was based on any independent inquiry or material that Assessing Officer might had collated for purposes of forming an opinion as to whether income in relevant AYs had escaped assessment, impugned reassessment notice was to be set aside [Assessment years 2013-14 to 2017-18] [In favour of assessee] [Article 5 of DTAA between India and Switzerland]

GE Grid (Switzerland) GMBH v. Asstt. CIT [2025] 172 taxmann. com 227 (Delhi)

Assessee-company was incorporated and registered under the laws of Switzerland. It was engaged in the business of supplying equipments and spares to Indian entities. A survey was conducted upon company GE in June, 2019 which revealed that assessee had a business connection as per the Income-tax Act as well as a PE in India as per India-Switzerland DTAA and, thus, a part of its business profits arising from India was to be taxed in India as income of PE. Accordingly, Assessing Officer issued a reassessment notice. It was noted that revenue had woefully failed to establish that formation of opinion was based on any independent inquiry or material that Assessing Officer might had collated for the purposes of forming an opinion as to whether income in AYs 2013-14 to 2017-18 had escaped assessment. As was ex facie evident from a reading of reasons which stood assigned for invoking section 148, solitary basis was survey conducted in June 2019.

Held, on facts, that the impugned reassessment notice issued against the assessee was to be set aside.

Liaison office

46. Where assessee, a US based company, engaged in business of rendering money transfer services, established a liaison office (LO) in India, since activities undertaken by LO were merely preparatory or auxiliary in character and far removed from core business of assessee, LO would not constitute a PE [Assessment years 2001-02 to 2004-05, 2006-07, 2007-08, 2011-12, 2013-14 and 2015-16] [In favour of assessee] [Article 5 of the DTAA between India and USA]

DIT (International Taxation) v. Western Union Financial Services Inc. [2024] 169 taxmann.com 461/[2025] 472

ITR 220 (Delhi)

Assessee, a US-based company, was engaged in the business of rendering money transfer services. For the said purpose, it had entered into agreements appointing agents in India. In terms of agency agreements, assessee had established a liaison office (LO) in India. Assessing Officer opined that assessee had a fixed place of business which constituted a ‘Fixed Place’ PE. Tribunal held that the activities undertaken by LO were merely preparatory or auxiliary in character and, thus, it would not constitute a PE.

Held that the permission granted by RBI proscribed LO from undertaking any commercial, trading or industrial activity in India and since activities undertaken by LO were far removed from core business of assessee, tests of ‘preparatory’ and ‘auxiliary’ as embodied in Article 5(3)(e) stood satisfied and, thus, LO would not constitute a PE. Further, since LO did not have any authority to conclude contracts, it could not be classified as a DAPE. Furthermore, since software merely constituted a medium of communication which enabled Indian agents to talk and communicate with servers of assessee housed in USA, deployment of software would not result in creation of a PE.

47. Where Liaison Office (LO) of assessee in India did not finalize and transact a business deal on its own or in name of head office, activities carried out by LO could not be said to be preparatory or auxiliary in nature and, thus, LO did not constitute Permanent Establishment of assessee [Assessment year 2009-10] [In favour of assessee] [Article 5 of DTAA between India and Japan]

CIT (International Taxation)-2 v. Mitsui and Co. [2025] 170 taxmann.com 827 (Delhi)

Where liaison office of assessee, a Japanese company, in India did not finalize and transact a business deal on its own or in the name of head

office, activities carried out by LO could not be said to be preparatory or auxiliary in nature and, thus, LO did not constitute Permanent Establishment, liable to tax in India.

48. Where Assessing Officer issued reopening notice based on materials gathered during survey conducted for earlier assessment years at Indian LO of non-resident assessee, and held that LO constituted a fixed place PE of assessee in India and income attributable to such PE was taxable in India, since assessee did not assert that facts in relevant assessment year were distinct from those which had fallen for detailed examination of revenue and had ultimately culminated in passing of a judgment by High Court in earlier assessment years, impugned reassessment proceedings were justified [Assessment year 2009-10] [In favour of revenue] [Articles 5 and 7 of DTAA between India and Italy]

GE Nuovo Pignone S.P.A v. CIT (International Taxation) [2024] 167 taxmann.com 351/[2025] 477 ITR 659 (Delhi)

Assessee was a non-resident company incorporated in Italy and part of GE group. A survey was conducted at LO of assessee’s group company and based on material gathered in the course thereof, notices under section 148 came to be issued to various entities of GE Group including assessee for assessment years 2001-02 to 2008-09. Thereafter, Assessing Officer issued reopening notice for the relevant assessment year on the ground that LO constituted a fixed place PE of assessee in India and income attributable to such PE was taxable in India. Assessee contended that the entire reassessment action was based upon the survey report and material which had been gathered and collated for assessment years other than the relevant assessment year and could not have justifiably formed the basis for invocation of section 148. It was noted that assessee did not assert that the facts in the relevant assessment year were distinct or distinguishable from those which had fallen for detailed examination of revenue in litigation which had ensued and had ultimately culminated in passing of a judgment by the High Court in earlier assessment years holding that assessee had a PE in India.

Held that the impugned reassessment proceedings were justified. Case review : GE Nuovo Pignone SPA v. Deputy CIT (IT) [2019] 101 taxmann. com 402 (Delhi - Trib.) affirmed

Secondment of employees

49. Where assessee, a South Korean company, had seconded employees in India, however, those employees were not discharging functions or performing activities connected with global enterprise of assessee and their placement in India was with objective of facilitating activities of Indian subsidiary, those employees would not meet qualifying benchmarks of a PE [Assessment years 2007-08 to 2009-10, 2011-12 to 2015-16 and 2017-18] [In favour of assessee] [Article 5 of DTAA between India and South Korea]

Pr. CIT, International Taxation v. Samsung Electronics Co. Ltd. [2025] 170 taxmann.com 417/303 Taxman 212/478 ITR 271 (Delhi)

Assessee, a South Korean company, was engaged in manufacturing and sale of electronic goods. It had two wholly owned subsidiaries in India. Assessing Officer held that Indian subsidiary was liable to be considered as a PE per se. He also held that the said subsidiary met tests of DAPE as well as service PE. Tribunal noted that seconded employees were not discharging functions or performing activities connected with the global enterprise of assessee. Their placement in India was with the objective of facilitating activities of Indian subsidiary and, thus, collection of market information, collation of data for development of products, market trend studies or exchange of information would not meet the qualifying benchmarks of a PE.

Held that the Tribunal was justified in interfering with the opinion formed by DRP which had spoken of a deemed PE having come into being merely on account of secondment of employees.

Case review : Samsung Electronics Co. Ltd. v. Dy. CIT (Int. Taxation) [2018] 92 taxmann.com 171/64 ITR(T) 99 (Delhi - Trib.) affirmed.

Strategic oversight services agreement

50. Where assessee, a Dubai based company, entered into an agreement with Indian hotel to provide strategic planning and ‘know-how’ to ensure that hotel was developed and operated efficiently, since assessee exercised pervasive and enforceable control over hotel’s strategic, operational, and financial dimensions, hotel premises satisfied criteria required to be classified as a “fixed place of business” or PE within meaning of article 5(1) of DTAA and, thus, income received under SOSA was attributable to such PE and was taxable in India [Assessment years 2009-10 to 2017-18] [In favour of revenue] [Articles 5 and 7 of the DTAA between India and UAE]

Hyatt International Southwest Asia Ltd. v. Addl. DIT [2025] 176 taxmann.com 783/306 Taxman 241/478 ITR 238 (SC)

Assessee, a company incorporated in Dubai, entered into two Strategic Oversight Services Agreements (SOSA) with ASL, India. Under the

said agreement, assessee agreed to provide strategic planning and ‘know-how’ to ensure that hotel was developed and operated efficiently. Assessing Officer passed assessment orders taxing hotel related services rendered by assessee, inter alia, on the ground that assessee had a PE in India in form of place of business under article 5(1) of DTAA. High Court upheld the order passed by the Assessing Officer. It was noted from contractual provisions detailed in SOSA that assessee exercised pervasive and enforceable control over hotel’s strategic, operational, and financial dimensions. It was also noted that assessee’s executives and employees made frequent and regular visits to India to oversee operations and implement SOSA.

Held that the 20-year duration of SOSA, coupled with assessee’s continuous and functional presence, satisfied the tests of stability, productivity and dependence and, thus, hotel premises clearly satisfied the criteria required to be classified as a “fixed place of business” or PE. Furthermore, assessee’s ability to enforce compliance, oversee operations, and derive profit-linked fees from hotel’s earnings demonstrated a clear and continuous commercial nexus and control with hotel’s core functions which satisfied conditions necessary for constitution of a fixed place PE under Article 5(1) of India-UAE DTAA. Thus, assessee had a fixed place PE in India within the meaning of article 5(1) of DTAA and income received under SOSA was attributable to such PE and taxable in India.

Case review : Hyatt International-Southwest Asia Ltd. v. Addl. DIT [2024] 158 taxmann.com 136/297 Taxman 497/464 ITR 508 (Delhi) affirmed.

51. Where assessee, an insurance company, made payments towards reinsurance premium to Non-Resident Reinsurers (NRRs) without deducting tax at source, since brokers were acting as independent entities merely playing role of facilitators, no tax at source was to be deducted on these payments, thus, impugned payments made by assessee to NRRs could not be disallowed under section 40(a)(i) [Assessment years 2005-06 to 2010-11, 2013-14 and 2014-15] [In favour of assessee] [Article 5 of the DTAA between India and Switzerland]

Pr. CIT - 4 v. Cholamandalam MS General Insurance Company Ltd. [2025] 175 taxmann.com 452 (Mad.)

Assessee was an insurance company carrying on reinsurance business. It made payments towards reinsurance premium to non-resident reinsurers (NRRs) without deducting tax at source. Assessing Officer disallowed such payments under section 40(a)(i) for non-deduction of TDS under section 195. It was noted that the discussion in the order

of Tribunal sat out the relevant facts making it clear that brokers were acting as independent entities merely playing the role of facilitators. Tribunal, thus, concluded that brokers did not either constitute a business connection in terms of Explanation 2 to section 9(1)(i) or a Permanent Establishment in terms of article 5 of relevant DTAAs.

Held that no material was produced by the Department before the court to dislodge factual findings rendered by the Tribunal. Thus, the impugned payments made by assessee to NRRs could not be disallowed under section 40(a)(i).

REASSESSMENT

52. Where reassessment proceedings were initiated against assessee on ground that non-resident parent company and its affiliates had a business connection and a PE in India and, thus, assessee was liable to deduct tax under section 195 on payments made by it to them, since subsequent order passed under section 201(1) found that except for one, all other affiliates did not have a PE in India, impugned reassessment proceedings were to be quashed [Assessment years 2006-07 and 2007-08] [In favour of assessee] [Article 5 of OECD Model Convention]

Honda Cars India Ltd. v. Dy. CIT [2024] 166 taxmann.com 623/301

Taxman 653 (Delhi)

Assessee-company was engaged in the business of manufacturing and selling of cars in India. It filed its return of income which was accepted and an assessment order was passed. Subsequently, a survey was conducted upon assessee and on the basis of same, reassessment proceedings were initiated against the assessee on the ground that nonresident parent company and its affiliates had a business connection and a PE in India and, thus, assessee was liable to deduct tax under section 195 on payments made by it to them and since assessee had failed to do so, provisions of section 40(a)(i) were attracted and amount claimed as expenditure was liable to be disallowed under section 40(a) (i). Assessee submitted that subsequent order dated 10-12-2018 passed under section 201(1) found that except for one, all other affiliates did not have a PE in India.

Held, on facts, that the impugned reassessment proceedings initiated against the assessee were to be quashed.

BUSINESS PROFITS [ARTICLE 7 OF OECD MODEL CONVENTION]

PROFITS ATTRIBUTABLE TO PE, COMPUTATION OF

53. Where issue regarding attribution of profit to AE on merits already stood concluded in favour of assessee by Court in earlier year, questions raised in Revenue’s appeal having become academic, appeal under section 260A was not maintainable [Assessment year 2011-12] [In favour of assessee]

CIT, International Taxation-3 v. Travelport LP [2025] 179 taxmann. com 613 (Delhi)

Assessing Officer held that assessee had a PE in India and profit of 100% was attributed to the assessee. Tribunal, however, held that the provisions of section 144C with all its sub-section did not apply to assessee, and so assessment order was void ab initio. Tribunal also held that even on the merits of the case, assessee had to succeed inasmuch as findings given by the Assessing Officer was totally based upon findings given in earlier assessment years and assessee was not responsible to explain recipients of receipts shown in Form No. 26AS. It was noted that in assessee’s case for earlier AYs, namely, CIT, International Taxation v. Travelport L.P. USA [2024] 158 taxmann.com 351 (Delhi), it was held that since assessee had not deployed any assets in India and major part of business activities took place in USA, Appellate Authority was justified in holding that 15 per cent of assessee’s profit was to be attributed to India.

Held that since the issue on merits already stood concluded in favour of assessee by Court in earlier year, questions raised in Revenue’s appeal having become academic, appeal under section 260A was not maintainable.

Global net loss

54. For computing profits attributable to Indian PE of assessee, net profit margins of assessee were to be applied and since assessee recorded a global net loss in relevant assessment year, no profit/income would be attributable to PE [In favour of assessee] [Articles 5 and 7 of the India-Finland DTAA]

CIT (International Taxation) v. Nokia Solutions and Networks OY [2023] 147 taxmann.com 165/455 ITR 157 (Delhi)

For computing the profits attributable to Indian PE of assessee, a Finland based company, net profit margins of assessee were to be applied and since assessee recorded a global net loss in the relevant assessment year, no profit/income would be attributable to PE.

Taxmann's Yearly Tax Digest & Referencer

Sample Read

SECTIONS 10 TO 10C

SECTIONS 11 TO 13

SECTIONS 15 TO 17

SECTIONS 22 TO 27

SECTIONS 28 & 29

SECTIONS 40, 40A & 43B

SECTIONS 45 TO 55A

SECTIONS 56 TO 59

SECTION 69

SECTION 69A

SECTION 69B

SECTION 69C

SECTIONS 70 TO 80

SECTIONS 80A TO 89A

SECTION 90

SECTIONS 115J TO 115JB

SECTIONS 119, 124 & 127

SECTIONS 131 TO 138

SECTION 139AA

SECTION 142

SECTIONS 143 & 144

SECTION 144B

SECTIONS 145 & 145A

SECTIONS 147 TO 153

SECTIONS 153A TO 153D

SECTIONS 158B TO 158BI

SECTIONS 159 TO 179

SECTIONS 184 TO 189A

SECTIONS 190 TO 206C & 234E

SECTIONS 220 TO 226

SECTIONS 234A TO 234C

SECTIONS 237 TO 245

SECTIONS 245A TO 245M

SECTION 245MA

SECTIONS 246 TO 251

SECTIONS 252 TO 255

SECTIONS

SECTION 268A

SECTION 269ST

SECTIONS 269U TO 269UP

SECTIONS 270A TO 275

SECTIONS 275A TO 279A

SECTION 281B

OTHER ACTS /RULES/SCHEMES

WORDS AND PHRASES

SECTION 9

SECTIONS 10 TO 10C

SECTIONS 11

SECTION 14A

SECTIONS 15 TO 17

SECTIONS 22 TO 27

SECTIONS 28 & 29

SECTION 35DDA

SECTION 35E

SECTIONS 40, 40A & 43B

SECTIONS 45 TO 55A

SECTIONS 56 TO 59

SECTION 69

SECTION 69A

SECTION 69B

SECTION 69C

SECTIONS 70 TO 80

SECTIONS 80A TO 89A

SECTION 90

SECTIONS 92 TO 92F & 144C

SECTION 94B

SECTION 115-O

SECTIONS 115QA TO 115QC

SECTION 115U

SECTIONS 115V TO 115VZC

SECTIONS 120, 124 & 127

SECTIONS 131 TO 138

SECTION 142

SECTIONS 143 & 144

SECTION 144B

SECTIONS 145 & 145A

SECTIONS 147 TO 153

SECTIONS 153A TO 153D