Landmark case starting points with authority, issue and practical crux.
| Case | Authority | Issue | Finin2min crux | Year | Reliance note |
|---|---|---|---|---|---|
| Union of India v. Azadi Bachao Andolan | Supreme Court | Treaty entitlement and treaty shopping | Treaties operate through domestic enabling law; substance and later anti-abuse developments must still be checked. | 2003 | Check subsequent history before reliance |
| Vodafone International Holdings BV v. Union of India | Supreme Court | Indirect transfer and legal form | The Court examined offshore share transfer and look-at principles; later statutory indirect-transfer provisions materially affect current analysis. | 2012 | Check subsequent history before reliance |
| Formula One World Championship Ltd. v. CIT | Supreme Court | Fixed place PE | Control and disposal of the race circuit during the event supported a PE finding on the facts. | 2017 | Check subsequent history before reliance |
| ADIT v. E-Funds IT Solution Inc. | Supreme Court | Subsidiary and service PE | A subsidiary is not automatically a PE; the revenue must establish treaty conditions. | 2017 | Check subsequent history before reliance |
| Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT | Supreme Court | Software payments | Payments for specified copyrighted software arrangements were not royalty under the examined treaty/domestic framework. | 2021 | Check subsequent history before reliance |
| Morgan Stanley & Co. Inc. v. DIT | Supreme Court | Service PE and attribution | The Court addressed stewardship, deputation, service PE and arm’s-length attribution. | 2007 | Check subsequent history before reliance |
| DIT v. Morgan Stanley / SET Satellite line of cases | Supreme Court / High Courts | PE profit attribution | Arm’s-length remuneration may be central but fact-specific residual attribution must be tested. | 2007 onward | Check subsequent history before reliance |
| Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT | Delhi High Court | Marketing intangibles and aggregation | The Court examined aggregation, comparables and marketing expenditure in distribution arrangements. | 2015 | Check subsequent history before reliance |
| CIT v. EKL Appliances Ltd. | Delhi High Court | Intra-group services | Commercial expediency is not substituted by the TPO; receipt/benefit and arm’s-length price still require evidence. | 2012 | Check subsequent history before reliance |
| Nestle SA treaty MFN litigation | Supreme Court | MFN clause operation | The Supreme Court required legal notification conditions for the examined MFN benefit; treaty/protocol status must be checked country by country. | 2023 | Check subsequent history before reliance |
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