Dr. Ajit Kumar Singh

Dr. Ajit Kumar Singh, is an IRS Officer and serving as Principal Commissioner of Income Tax Delhi. He did his PhD in Law from the National Law University Delhi; Programme on Corporate Taxation and Advocacy at Duke University, USA; MSc in Law and Finance, University of Oxford, United Kingdom; LLB from Delhi University; Master of Arts in English Literature from Hindu College, Delhi University; Bachelor of Arts ( Hons.) in English Literature from Hindu College, Delhi University.

Dr. Singh has more than 33 years of experience in Tax administration and has worked in various capacities as Assistant Commissioner, Deputy Commissioner, Jt. Commissioner, Addl. Commissioner, Commissioner, and presently the Principal Commissioner of Income-tax, Delhi.

During 2020-2023, he headed the Dispute Resolution Panel of the Government of India, adjudicating on international taxation disputes. Passed nearly 2000 adjudicatory orders on international tax disputes. Dr. Singh served on various committees, most notable being the Committee on Change Management. He was Senior Departmental Representative, Income Tax Appellate Tribunal, arguing legal taxation issues before the tribunal. He has Special knowledge of corporate law and law relating to corporate transactions with an international perspective.

His Publications includes:

• Singh, Ajit Kumar, Exploring the Nexus Doctrine in International Taxlaw, (Wolters Kluwer, 2021)

• Singh, Ajit Kumar, ‘Resolving the Hamletian Dilemma: Can Non-consideration of an Argument in Appeal Trigger Rectificatory Jurisdiction in Indian Tax Law?’, VISION: Journal of Indian Taxation, Vol 10(2), Jul-Dec 2023, pp. 1-13
• Singh, Dr. Ajit Kumar, ‘Validity of the Exercise of Rectificatory Jurisdiction by DRP at Instance of TPO: A Look at Shapoorji Pallonji Case’, [2023] 150 taxmann.com 64
• Singh, Ajit Kumar, ‘Fees for Technical Services and the Absence of ‘Make Available Clause’ in Tax Treaties: Can a Protocol Not Notified by the Government Trigger the ‘Most Favoured Nation Clause’, VISION: Journal of Indian Taxation, Vol. 9(2), Jun-Dec 2022, pp. 25-38
• Singh, Ajit Kumar, ‘Taxability of Receipts from Live Transmission Rights as Royalty under the Domestic Law: A Critique of the Tax Tribunal Decision in the Fox Network Group Case,’ VISION: Journal of Indian Taxation, Vol. 9(1), Jan-Jun 2022, pp. 15-30
• Singh, Ajit Kumar, ‘International Tax Disputes and the Ouster of General Limitational Rules in the Dispute Resolution Mechanism in Indian Tax Law,’ VISION: Journal of Indian Taxation, Vol. 8(1), Jan-Jun2021, pp. 19-37.
• Singh, Ajit Kumar, ‘The Education Cess Conundrum: A Critique of Sesa Goa and Chambal Fertilisers Decisions’,[2020] 120 taxmann.com 366 (Article)
• Singh, Ajit Kumar, ‘Attribution of Profits to PEs: The Authorised OECD Approach & A Look at the Indian SC Holdings in Morgan Stanley’, [2019] 109 taxmann .com 32 (Article)
• Singh, Ajit Kumar, ‘Non-resident Taxation in India: Some Legal Issues on Tax Deduction’ [2019] 102 taxmann.com 389 (Article)
• Singh, Ajit Kumar, ‘Profits from Operation of Ships and Aircrafts in International Traffic under Article 8 of India’s Tax Treaties’[2019] 102 taxmann.com 390 (Article)
• ‘Risk Adjustment in Transfer Pricing Comparability Analysis[2020] 118 taxmann.com 236 (Article)’

•  Singh Ajit Kumar and Nair Anita, ‘Finding the Meaning of Nexus for Taxes – Past, Present, and Future,’ Cahiers De Droit Fiscal International, Studies on International Fiscal Law by the International Fiscal Association 2024, Volume 108, IFA Congress2024 (Cape Town, South Africa)