NCR Global Solutions Ltd. vs DCIT Tax Dispute 2018-19

In the matter of ITA No. 1756/DEL/2022 & 1776/DeL/2022, NCR Global Solutions Limited, based in Ireland, squared off against the Deputy Commissioner of Income-tax, Circle-2(2)(2), International Taxation, New Delhi, regarding disputes for the Assessment Year "2018-19". The case was presided over by Shri G.S. Pannu, President, and Shri Kul Bharat, Judicial Member of the Income Tax Appellate Tribunal, Delhi Bench.

This case highlights the complexities of international taxation, specifically around the issues of Permanent Establishments (PE) and the attribution of profits to a PE, including the transfer pricing aspects concerning the sales of software and hardware. NCR Global Solutions Limited (the appellant) filed appeals against the orders passed by the Assessing Officer under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961, dated 06.06.2022 and 09.06.2022 for the Assessment Years 2018-19 and 2019-20.

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[The article content here would normally proceed to detail the grounds of the appeal, submissions made by both the appellant and respondent, legal arguments, analysis of these arguments in the light of statutory provisions and judicial precedents, the tribunal’s observations, and the final verdict of ‘Partly Allowed.’]

NCR Global Solutions Ltd. vs DCIT Tax Dispute 2018-19