Formula One World Championship Ltd. v. Commissioner of Income Tax, International Taxation-3, Delhi & Anr.

Source & verification

Download original judgment / order · Open cited source rendition

Identified source rendition: 68 PDF pages; SHA-256 deb206ae781a3d17ee9d476af3d9922f243c8327f0b4d55a6cc2f4d86a0e8261. Original bytes preserved. Paragraphs 1-81 on physical PDF pages 7-68 (SCR 158-219). Pages 1-6 and the beginning of page 7 are editorial headnote, case-law, identity and appearance material. No neighbouring judgment within the judicial boundary.

• No numerical assessment year is identified in the bounded judicial text. This is a transaction-based advance-ruling dispute concerning the RPC of 13 September 2011. Paragraph 10 records races in 2011, 2012 and 2013; those event years are not converted into inferred assessment years.
• The SCR rendition gives only lead Civil Appeal No. 3849 of 2017, identifiable as FOWC's appeal. The official Enscript caption and appended record confirm companion Civil Appeal Nos. 3850 and 3851 of 2017. The inspected captions do not individually assign those two numbers to Jaypee and Revenue; no allocation is inferred from listing order. The disposition is separated by appellant below.
• Section 9(1)(i), including the discussion of Explanation 1(a) attribution and Explanations 2 and 4, supplies the domestic business-connection framework; section 195 and subsection (2) concern withholding on the chargeable component. Sections 4, 5 and 6 are background, and section 92F(iiia) is a contextual definition, not an independent transfer-pricing holding. Section 9(1)(vi) is expressly skipped because the RPC royalty finding was unchallenged. Section 201 and advance-ruling provisions arise in Jaypee's submissions; no interest or penalty immunity is granted. Sections 195(3), 199 and 237 appear through the GE India discussion/quotations, without a separate new ruling. The printed reference to section 245QQ in paragraph 53's continuation is not promoted into an operative statutory tag.
• The 68-page preserved SCR rendition is the substantive primary source. Headnotes and case-law tables are editorial, not the Court's reasoning. Its judicial paragraphs 1-81 and physical pages are used throughout.; The official Supreme Court Enscript rendition was checked only for metadata on physical pages 1 and 50. It confirms all three appeal numbers, but does not identify which of the two companion numbers belongs to Jaypee and which to Revenue. No such allocation is invented.; There are apparent drafting/rendition inconsistencies: paragraph 38 says ten years for the rights transfer while paragraphs 9, 68 and 73 describe a hundred-year structure; FOM/FOAM references and the direction of the service arrangement vary. This note does not silently reconstruct or certify a corporate-contract chain from those inconsistencies.; The RPC clause 11 states fourteen days before and seven days after the race. The adopted High Court passage also describes access up to six weeks. Both are source formulations; the note does not silently equate them or derive an exact general day threshold.; Paragraph 21's last sentences refer to an independent agent inconsistently with the immediately quoted Article 5(5), and paragraph 35 introduces its examples as negative although some describe PEs. Rely on the actual treaty wording and the final issue disposition, not those introductory labels.; Physical page 60 is visually distorted and its OCR is poor; the relevant RPC controls were visually checked and cross-checked against the earlier, clearer clause extracts on pages 35-38.; The leading statement in paragraph 77 about non-resident payments must be read with paragraph 78's express chargeability/attribution limit. This note does not state that every foreign remittance requires deduction or that every wholly non-chargeable payment requires a section 195(2) order.; No numerical assessment year is supplied. The treaty and statutory text are those discussed in this historical proceeding; no current consolidated-text or comprehensive subsequent-law verification is claimed.; E-Funds quotes Formula One using a different paragraph numbering: its quotation labelled 32 corresponds to paragraph 27 of this preserved Formula One rendition. This note uses the actual paragraph numbers in each cited source; it does not silently transpose them.; The search for official metadata incidentally surfaced a later banking-guarantee case, but that case was not substantively reviewed and no later-treatment conclusion is drawn from the search snippet.

Statutory scope

Historical 1961 Act/India-UK treaty and transaction-specific PE decision. No automatic mapping to the Income-tax Act, 2025 or assertion that present treaty/statutory wording is identical.

Later treatment

Source checked 2026-10-04. Only the bounded E-Funds disposal-test comparison specified above was checked. No comprehensive later-treatment, post-assessment outcome, treaty-amendment or current-law audit was performed.

Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.

Identified source links

• reported judgment — PDF 68 pages

  SHA-256: deb206ae781a3d17ee9d476af3d9922f243c8327f0b4d55a6cc2f4d86a0e8261

• reported judgment — PDF 42 pages

  SHA-256: 212dda4e3430bfd30eb1de41af44e0460158b3232fe0f561cd23b0626be1aee2

• official court enscript rendition — PDF 50 pages

  SHA-256: d3fb9833540084fa37887cd3b0922fbc5d24fd6ef71078341be9ff78534d0c11

Related reviewed notes

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