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September 8, 2026   Case Laws GST
Inverted duty refunds cover higher-taxed packing materials used for packaged tea despite an inapplicable GST rate-reduction circular.
September 8, 2026   Case Laws GST
Pure-agent electricity recovery excludes actual, unmarked-up metered and common-area charges from the taxable value of premises maintenance services.
September 8, 2026   Case Laws GST
Prior adjudication bars advance-ruling applications on identical GST classification and rate questions concerning the applicant.
September 8, 2026   Case Laws GST
Classification of ruled paper sheets keeps them under Heading 4802; notebook-use exemption depends on actual manufacture.
September 8, 2026   Case Laws GST
End-use GST exemption for uncoated paper depends on proven manufacture of specified books, while other uses remain taxable.
September 8, 2026   Case Laws Income Tax
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an incorrect authority.
September 8, 2026   Case Laws Income Tax
Director tax liability under Section 179 requires consideration of the director's reply before liability can be determined lawfully.
September 8, 2026   Case Laws Income Tax
Capital-gains exemption requires a qualifying asset transfer and reinvestment by the same assessee, not solely by a spouse.
September 8, 2026   Case Laws Income Tax
Live sports broadcasting rights exclude live-feed payments from royalty, while non-live rights remain taxable and require withholding.
September 8, 2026   Case Laws Income Tax
Deductee-paid-tax exception requires verification before TDS default and consequential interest apply to External Development Charges payments.
September 8, 2026   Case Laws Income Tax
Section 50C valuation date follows crystallised consideration where rehabilitation arrangements precede registration, preventing enhanced capital gains additions.
September 8, 2026   Case Laws Income Tax
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment.
September 8, 2026   Case Laws Income Tax
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments.
September 8, 2026   Case Laws Income Tax
MEIS export rewards are revenue income because they offset business costs rather than fund capital investment or expansion.
September 8, 2026   Case Laws Income Tax
TDS credit for trust income remains available despite trustee PAN reporting and absence of Rule 37BA declaration.
September 8, 2026   Case Laws Income Tax
Stale Reassessment Material Cannot Support Reopening When Earlier Proceedings Already Considered the Same Lender-Credit Information
September 8, 2026   Case Laws Income Tax
Block-period computation for non-searched persons rendered out-of-period assessments void for lack of jurisdiction under the search assessment regime.
September 8, 2026   Case Laws Income Tax
Sufficient Cause for Delay Requires Bona Fide Diligence, Leaving a Decade-Late Exemption Appeal Unheard on Merits
September 8, 2026   Case Laws Income Tax
Remand limitation periods require fresh-assessment timelines where Tribunal directions mandate fresh consideration, while unexplained foreign currency remains taxable income.
September 8, 2026   Case Laws Income Tax
Return-processing adjustments cannot tax validly applied accumulated charitable income merely because electronic return fields contain reporting mismatches.

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Home › Highlights › Income Tax › 2024 › May, 2024 › This
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Income Tax

The Delhi High Court examined taxability in India of interest...

Delhi High Court rules Indian PE interest from Head Office non-taxable under India-US DTAA; rejects 2016 Explanation's application.

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Income Tax May 31, 2024 Case Laws HC
The Delhi High Court examined taxability in India of interest received by an Indian Permanent Establishment (PE) from its Head Office/Overseas Branch under the India-US Double Taxation Avoidance Agreement (DTAA). The court referred to the Credit Agricole case, emphasizing that branch offices are not separate legal entities. The court noted that the Explanation to Section 9(1)(v) of the Income Tax Act deals with banking entities, deeming remittances to the Head Office as accruing in India. The court found that the PE of a banking enterprise is not a separate legal entity, rejecting the application of the Explanation introduced in 2016. Referring to the Kikabhai Premchand KT case, the court highlighted the absurdity of a person profiting from itself. The court upheld the view that the branch office cannot profit from itself, and the DTAA provisions for banking enterprises would apply.
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