WABCO INDIA LTD. vs. DCIT (INTERNATIONAL TAXATION) (2018) 407 ITR 317 (Madras HC); 97 taxmann.com 620 (Madras):

The assessee was incorporated under the Companies Act, 1956 and is engaged in the business of designing, manufacturing and marketing various auto components.  The company is on the stock exchange. In 2012-13, 75% of the shares of the Appellant were held by Clayton Dewandre (“CD”) and the balance 25% were held by public. In 2013-14, […]

SUPREME COURT DECISION IN THE CASE OF ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD V DIT [2007] 288 ITR 408 (SC) / (2007) 3 SCC 481 – ANALYSIS AND LEARNINGS

Background The Assessee is a company incorporated in Japan.  It is engaged, inter alia, in the business of construction of storage tanks as also engineering etc.  It formed a consortium with various parties and entered into an Agreement with Petronet LNG Limited (“LNG Petronet”) on 19-1-2001 for setting up a Liquefied Natural Gas (LNG) receiving, […]

EVOLUTION OF TERRITORIAL NEXUS UNDER GOVERNMENT OF INDIA ACTS

Territorial Nexus – Concept The concept of Sovereignty outlines a nation’s exclusive right to govern itself without interference from other Nations.  As a general principle laws made by one State have no operation in any other state. The advancement in science and technology have led to a substantial increase in trade, commerce, services. There is […]

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