Toyota Tsusho Corporation vs. DCIT(Int. Tax.)
Parties Involved
Facts Summary
The assessee, Toyota Tsusho Corporation, a company incorporated and fiscally domiciled in Japan, filed appeals against the orders passed by the Commissioner of Income Tax (Appeals)-43, New Delhi, under section 250 of the Income Tax Act, 1961. The assessee challenged the orders for three assessment years: 2013-14, 2015-16, and 2016-17. The assessee argued that the Assessing Officer had wrongly attributed various receipts to a Supervisory Permanent Establishment (PE) in India. The Revenue, on the other hand, challenged the relief granted by the Commissioner of Income Tax (Appeals). The main issues revolved around the existence of a Supervisory PE in India, the taxability of offshore supply profits, and the treatment of reimbursement of expatriate salary.…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Existence of Supervisory PE in India
- 2. Taxability of offshore supply profits
- 3. Treatment of reimbursement of expatriate salary
Judgment Outcome
Decided in favour of Partly Assessee / Partly Revenue.
Precedents Relied Upon
5 precedents cited in this judgement.
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