The Resource Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011

Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011

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Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011
Title
Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011
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Subject
Language
eng
Summary
Judgment by the High Court of Delhi at New Delhi, judgment date 5 February 2014. The taxpayers were companies resident in the US. They paid income tax on their global income in the US. Through a series of holding companies, the taxpayers owned a subsidiary in India, "e-Fund India". The taxpayers entered into contracts with e-Fund India. E-Fund India was taxed on its global income in India and the transactions with the taxpayers were the subject of "arm's length" adjustication by the Revenue. The Revenue claimed that the taxpayers were liable to tax in India arguing on a number of grounds that they had a permanent establishment in India. India and the US resorted to the Mutual Agreement Procedure under art 27 of the India-US double taxation agreement and had agreed to the taxation of the income in India. The Revenue argued that this meant that the issue could not be relitigated
Citation source
In: International tax law reports. - London. - Vol. 16 (2014),
http://bibfra.me/vocab/relation/comm
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http://library.link/vocab/creatorName
Goradia, S
Geographic coverage
  • Asia
  • North America
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • PE
  • fixed place of business
  • MAP
Label
Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011
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Publication
Label
Director of Income Tax v e-Funds IT Solution and related appeals : Income Tax Appeal No 735/2011
Publication

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