| 19240700 | Section 9(1)(vi) Income deemed to accrue or arise in India - Under section 9(1)(vi) - Royalty - Rei -- AO held that reimbursement of lease line charges received by assessee would come within term |proces......
Del-HC -- 06 Oct 2025
CIT v. Expeditors International of Washington Inc. Appeal Dismissed
ITA No. 491/2025
2025 TaxPub(DT) 7299 (Del-HC)
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| 18979800 | Section 90 Article 12 Double taxation relief - Agreement between India and USA - Fees for Technic -- Assessee-LLP based at USA, had an arrangement for seconding employees to its Indian member firms, re......
Del-Trib -- 31 Jul 2025
Ernst & Young U.S. LLP v. ACIT Assessee Appeal Allowed
ITA No. 1254/Del/2025, ITA No. 1243/Del/2025
2025 TaxPub(DT) 5781 (Del-Trib)
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| 18997000 | Section 92C Transfer Pricing - Determination of ALP - Alternate adjustment proposed by TPO - -- TPO proposed an alternate adjustment for the Software Development services segment. This adjustment ......
Pune-Trib -- 18 Jul 2025
Spectraforce Technologies (India) (P) Ltd. v. ACIT Assessee Appeal Partly Allowed
ITA No. 2853/PUN/2024
2025 TaxPub(DT) 5920 (Pune-Trib)
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| 18979300 | Section 9(1)(vii) Income deemed to accrue or arise in India - Under section 9(1)(vii) - Fees for -- Assessee, a foreign company based at UK, received payments totaling Rs. 10,06,66,731 from HSBC Elect......
Mum-Trib -- 16 Jul 2025
Dy. CIT v. HSBC Bank PLC Revenue Appeal Dismissed
ITA No. 1538/MUM/2025
2025 TaxPub(DT) 5776 (Mum-Trib)
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| 18980600 | Section 92C Transfer Pricing - Determination of ALP - Interest paid to AE - -- TPO made certain adjustment with respect to interest paid by assessee-company to its AE on ECB loans......
Bang-Trib -- 07 Jul 2025
Gleason Works (India) (P) Ltd. v. CIT Assessee Appeal Allowed
IT(TP) No. 2140/Bang/2024
2025 TaxPub(DT) 5789 (Bang-Trib)
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| 18803800 | Section 90 Article 5(4) Double taxation relief - Agreement between India and USA - Existence of D -- Assessee, a US-based company providing cloud-based security solutions, had an Indian subsidiary (Zsc......
Del-Trib -- 18 Jun 2025
Zscaler Inc. v. DCIT Appeal Allowed
ITA No. 3376/Del/2023 and ITA No. 928/Del/2025
2025 TaxPub(DT) 4716 (Del-Trib)
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| 18657000 | Section 90 Article 12(4) Double taxation relief - Agreement between India and USA - Fees for Inclu -- Assessee, a US-based company, operated an online platform offering educational courses from various ......
Del-Trib -- 29 May 2025
Coursera Inc. v. ACIT Assessee Appeal Allowed
ITA No. 1958/Del/2025
2025 TaxPub(DT) 3740 (Del-Trib)
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| 18737100 | Section 70 Section 111A Loss - Set-off of STCG from non-STT paid shares against STCL from STT paid s -- Assessee had both short-term capital gains (STCG) from the sale of shares on which Securities Transa......
Mum-Trib -- 23 May 2025
Vanguard Emerging Markets Stock Index Fund a Series of VISPLC v. ACIT Appeal Allowed
ITA Nos. 1277 to 1283/Mum/2025
2025 TaxPub(DT) 4280 (Mum-Trib)
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