About
Dr. Ajit Kumar Singh is an IRS Officer, serving as Chief Commissioner of Income Tax, Delhi. An Oxford alumnus, he did his MSc in Law and Finance from St. Hughs College, University of Oxford and LLB from Delhi University. He did his PhD in Law from NLUD.
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, Principal Commissioner of Income-tax and presently the Chief Commissioner of Income-tax, Delhi.
He is presently heading the Directorate General of Legal and Research in 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.
Areas of Interest:
- Taxation and Money Laundering Laws
- Law and Economics of Corporate Transactions
- Constitutional and Administrative Laws
Publications
Book:
- Singh, Ajit Kumar, Exploring the Nexus Doctrine in International Taxlaw, (Wolters Kluwer, 2021)
Articles:
- 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)
- 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)’
Assignments
Training/Courses Attended by Dr. Singh attended various training programs and the courses viz.
- OECD Course on Transfer Pricing and Audit of Multinational Companies at National Academy of Direct Taxes, Nagpur organized by the Government of India;
- OECD course on Exchange of Information & Bank Secret at National Academy of Direct Taxes, Nagpur;
- A Specialized course on Legal Drafting and Drafting of Judicial Orders at Regional Training Institute, Mumbai;
- Heavy Industries Operational Attachment Training at HRD Division, BHEL, Haridwar;
- A Specialised Course on Search and Seizure Assessment at Regional Training Institute, Lucknow.
