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Documents citing Commissioner Of Income Tax-Ii vs Mitsubishi Corporation India (P) Ltd on 6 February, 2009

Shivansh Kbuildcon Pvt. Ltd., Jaipur vs Acit, Jaipur on 6 November, 2017

(ii) CIT Vs Orissa Corporation (P) Ltd (1986) 159 ITR 79 (SC) The assessee had given named and addresses of the cash creditors, who were income tax assessees. Revenue apart from issuing summon u/s 131 notices to creditors, did not pursue the matter further- it did not examine creditworthiness of the creditors- assessee could not, under the circumstances do anything further. Held that the additions were rightly deleted.
Income Tax Appellate Tribunal - Jaipur Cites 116 - Cited by 2 - Full Document

Dcit, Jaipur vs Godawari Estates Pvt. Ltd., on 7 November, 2017

(ii) CIT Vs Orissa Corporation (P) Ltd (1986) 159 ITR 79 (SC) The assessee had given named and addresses of the cash creditors, who were income tax assessees. Revenue apart from issuing summon u/s 131 notices to creditors, did not pursue the matter further- it did not examine creditworthiness of the creditors- assessee could not, under the circumstances do anything further. Held that the additions were rightly deleted.
Income Tax Appellate Tribunal - Jaipur Cites 99 - Cited by 0 - Full Document

Rainbow Buildcon Pvt. Ltd., Jaipur vs Acit, Jaipur on 6 November, 2017

(ii) CIT Vs Orissa Corporation (P) Ltd (1986) 159 ITR 79 (SC) The assessee had given named and addresses of the cash creditors, who were income tax assessees. Revenue apart from issuing summon u/s 131 notices to creditors, did not pursue the matter further- it did not examine creditworthiness of the creditors- assessee could not, under the circumstances do anything further. Held that the additions were rightly deleted.
Income Tax Appellate Tribunal - Jaipur Cites 97 - Cited by 19 - Full Document

Zscaler Inc vs Deputy Commissioner Of Income Tax, ... on 23 December, 2025

27. Mr. Sawhney contested the submission made by the Revenue that, irrespective of the existence of a PE/business income in India, all Signature Not Verified Signed By:PRADEEP WP(C) No.10556/2025 Page 12 of 35 SHARMA Signing Date:23.12.2025 16:09:48 remittances made to non-residents are liable to withholding taxes under Section 195 of the Act and Explanation 2 to Section 195 of the Act, (inserted vide Finance Act 2012), by stating that firstly, under the scheme of the Act, no deduction may be required if the total income of the non-resident is not taxable India which was affirmed by the Supreme Court in Engineering Analysis Centre of Excellence (supra) following GE India Technology Centre (P) Ltd. v. CIT, (2010) 10 SCC 29, which held that, unless the total income is chargeable to tax under the Act, no withholding under Section 195 of the Act could be made; secondly, on the interpretation of Explanation 2 to Section 195 of the Act (inserted vide Finance Act 2012) a full bench of this Court in Commissioner of Income-tax v. Mitsubishi Corporation India (P.) Ltd., [2024] 463 ITR 335 (Delhi) (majority opinion) held that the obligation to deduct TDS under Section 195 of the Act only arises once the sum in question is chargeable to tax and Explanation 2 has no relevance to this settled position in law.
Delhi High Court Cites 57 - Cited by 0 - V K Rao - Full Document
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