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Documents citing Intelsat Global Sales And Marketing ... vs Dcit, Circle1(1), Chennai on 1 January, 2018

Angel Broking P.Ltd, Mumbai vs Dcit 4(1)(1), Mumbai on 28 February, 2018

IT A No . 54 3 3/ M/ 2 01 6 As s es s m e nt Ye ar : 20 0 9 - 1 0 provisions of section 94(7)were not examined nor invoked. Since the assessee has declared large amount of profits in transactions on purchase and sale of shares, this aspect could have genuinely missed the attention of persons concerned. For this, we rely on the judgment of coordinate Bench Mumbai Tribunal in the case of City Group Global Markets (P) Ltd. vs. ACIT Circle-4(2).ITA No.5352/Mum/2009 (supra). We also note that judgment relied by the ld DR for the Revenue is distinguishable on facts.
Income Tax Appellate Tribunal - Mumbai Cites 13 - Cited by 2 - Full Document

Ito (It) 1.2.2, Mumbai vs Bennet Coleman & Co Ltd, Mumbai on 14 January, 2026

Intelsat Earth Station Standards, eleven parameters, data pointing Intelsat Global Sales and Marketing Limited vs DCIT calculator are available in public domain and therefore do not constitute secret information or process. No confidential information is provided by the assessee to its customers to tax the receipts as process royalty. The assessee has placed the unredacted version of the Bennett Coleman & Co. Ltd. (A.Ys. 2018-19 and 2019-20) 17 customer contract (at pages 101 to 105 of the additional evidence) which clearly establishes that the redacted information i.e. allocated transponder, allocated bandwidth are merely commercial information. The amendment in section 9(i)(vi) of the Act vide Finance Act, 2012 cannot be read into the India- UK DAA. The impugned issue is also covered by the decisions (supra) of the Delhi High Court in the case of Intelsat Corporation and Asia Satellite Telecommunication Co. Ltd. The case of the assessee also finds support by the decision of the Delhi High Court in New Skies Satellite BV (2016) 68 taxmann.com 8 (Delhi HC). The Ld. DR has not brought on record any material to controvert the above submissions of the Ld. AR. In the light of the above factual matrix of the case and legal position set out above, we are of the considered view that the impugned receipts cannot be taxed as process royalty."
Income Tax Appellate Tribunal - Mumbai Cites 24 - Cited by 0 - Full Document

Ito (It) 1.2.2, Mumbai vs Bennet Coleman & Co Ltd, Mumbai on 14 January, 2026

Intelsat Earth Station Standards, eleven parameters, data pointing Intelsat Global Sales and Marketing Limited vs DCIT calculator are available in public domain and therefore do not constitute secret information or process. No confidential information is provided by the assessee to its customers to tax the receipts as process royalty. The assessee has placed the unredacted version of the Bennett Coleman & Co. Ltd. (A.Ys. 2018-19 and 2019-20) 17 customer contract (at pages 101 to 105 of the additional evidence) which clearly establishes that the redacted information i.e. allocated transponder, allocated bandwidth are merely commercial information. The amendment in section 9(i)(vi) of the Act vide Finance Act, 2012 cannot be read into the India- UK DAA. The impugned issue is also covered by the decisions (supra) of the Delhi High Court in the case of Intelsat Corporation and Asia Satellite Telecommunication Co. Ltd. The case of the assessee also finds support by the decision of the Delhi High Court in New Skies Satellite BV (2016) 68 taxmann.com 8 (Delhi HC). The Ld. DR has not brought on record any material to controvert the above submissions of the Ld. AR. In the light of the above factual matrix of the case and legal position set out above, we are of the considered view that the impugned receipts cannot be taxed as process royalty."
Income Tax Appellate Tribunal - Mumbai Cites 24 - Cited by 0 - Full Document

Ito (It)- 1.2.2, Mumbai vs Bennett Coleman & Co Ltd, Mumbai on 30 January, 2026

Intelsat Earth Station Standards, eleven parameters, data pointing Intelsat Global Sales and Marketing Limited vs DCIT calculator are available in public domain and therefore do not constitute secret information or process. No confidential information is provided by the assessee to its customers to tax the receipts as process royalty. The assessee has placed the unredacted version of the customer contract (at pages 101 to 105 of the additional evidence) which clearly establishes that the redacted information i.e. allocated transponder, allocated bandwidth are merely commercial information. The amendment in section 9(i)(vi) of the Act vide Finance Act, 2012 cannot be read into the India India-UK DAA. The impugned issue is also covered by the decisions (supra) of the Delhi High Court in the case of Intelsat Corporation and Asia Satellite Telecommunication Co. Ltd. The case of the as assessee also finds support by the decision of the Delhi High Court in New Skies Satellite BV (2016) 68 taxmann.com 8 (Delhi HC). The Ld. DR has not brought on record any material to controvert the above Bennett Coleman & Co Ltd. 15 ITA No. 7523/MUM/2025 submissions of the Ld. AR. In the light of the above ffactual matrix of the case and legal position set out above, we are of the considered view that the impugned receipts cannot be taxed as process royalty."
Income Tax Appellate Tribunal - Mumbai Cites 21 - Cited by 0 - Full Document

Intelsat Global Sales And Marketing ... vs Dcit Circle 1(2), Chennai on 12 February, 2021

Arising out of ITTPA Nos.39 to 49 /Chny/2018 Intelsat Global Sales and Marketing Limited vs. DCIT 5.0 Having heard both the parties and after having perused the material on record, we deem it fit to extend the Stays for a period of 180 days or the disposal of the appeals, whichever occurs earlier and also direct the Registry to fix the date of hearing on 14.04.2021. The assessee is also directed to file the relevant documents with the Revenue within two weeks. Since the date of hearing was announced in the presence of both the parties during the course of virtual hearing, the issuance of notices is hereby dispensed with.
Income Tax Appellate Tribunal - Delhi Cites 1 - Cited by 0 - Full Document
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