Supreme Court of India

Singapore Airlines Ltd. v. C.I.T., Delhi

Neutral citation
Reported as [2022] 9 S.C.R. 1
Bench Surya Kant and M. M. Sundresh JJ.
Decided 14 November 2022

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.

2 Supreme Court benches have cited this judgment.

What the Court ordered

We are of the view that in none of the 104 cases penalty was l eviable under Section 271C as the respondent in each case h as discharged its burden of showing reasonable cause for failure to deduct tax at source. 61.We find some parallels between the facts of the present ca se and the situation in Eli Lilly & Co. (Supra).

Judgment, page 40

From the headnote

Income Tax Act, 1961: s. 194H – Tax Deduction at the Source on Commission and brokerage – Interpretation of s. 194H – On facts, assessee airlines selling their flight tickets t hrough the travel agents – Arrangement between the airlines and the t ravel agents governed by Passenger Sales Agency Agreements, wher ein agents are entitled for 7% of the Base Fare as the Standard Co mmission, however, they were at liberty to set a price higher than th e Net Fare demanded by the airline and the additional amount that the trav el agents charged over and above the Net Fare that was quoted by the

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