Supreme Court of India
Director of Income Tax-ii (international Taxation) New Delhi & Anr. v. M/s. Samsung Heavy Industries Co. Ltd.
INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.
1 Supreme Court bench has cited this judgment.
From the headnote
Tax/Taxation – India-Korea Agreement for avoidance of double taxation of income and the prevention of fiscal evasion (DTAA) – Arts.5, 7 – Project Office whether a Permanent Establishment (PE) in India – Taxability of income – ONGC awarded turnkey contract to a consortium comprising of respondent-assessee, incorporated in South Korea for carrying out work w.r.t the Vasai East Development Project – Assessee set up a Project Office in Mumbai – For the relevant assessment year, assessee’s return of income showed nil profit alleging loss w.r.t activities carried out in India – Assessment Order…
Authorities it was built on
- 2007 M/s. Dit (international Taxation), Mumbai v. M/s. Morgan Stanley & Co.
- 2017 Assistant Director of Income Tax-i, New Delhi v. Mis. E-funds It Solution Inc.
- 2007 Commissioner of Income Tax, Meerut and Anr. v. M/s. Hyundai Heavy Industries Co. Ltd
- 2007 Ishikawajma-harima Heavy Industries Ltd. v. Director of Income Tax, Mumbai
Where later benches applied it
- 2021 Engineering Analysis Centre of Excellence Private Limited v. The Commissioner of Income Tax & Anr.
Of those, 1 mentioned
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