2011 (8) TMI 370 - ITAT AHMEDABAD
Joint Stock Company Zangas Versus ADIT (International Taxation), Ahmedabad
Applicability of section 115A(1)(b)(BB) and Section 9(1)(vii) - Business income or fee for technical services - services in relation to construction of pipeline project - PE in India - composite contract - Held that:- even if extra responsibility of ......
2011 (8) TMI 226 - AUTHORITY FOR ADVANCE RULINGS
Foster Pty. Ltd., In re
DTAA between India and Australia - Application for advance ruling when a case is pending before AO - Discretion of AAR - whether the consideration received/receivable by the applicant under the terms of the agreement with Ravva Oil Singapore is liabl ......
2011 (8) TMI 159 - ITAT MUMBAI
Income-tax Officer (IT) -TDS-3 Versus Bajaj Hindustan Ltd.
TDS u/s 195 - Fees for technical services - Assessee in default - According to the Assessing Officer the payment by the assessee to KPMG did not fall within the exceptions and, therefore, the payment would be income which accrues or arises in India i ......
2011 (8) TMI 30 - AUTHORITY FOR ADVANCE RULINGS
Columbia Sportswear Company, Versus Director of Income-tax (International Taxation), Bangalore
DTAA between India and USA - Permanent establishment - Liaison office - The activity of purchase is one that involves expenditure and is in no way related to generation of revenue. No revenue generating activity takes place in India and consequently ......
2011 (7) TMI 665 - ITAT MUMBAI
Deputy Director of Income-tax (Exemption), Range-II(2) Versus St. Xavier´s Education Trust
Whether additions in the assessment or the fact that the assessee did not file appeal can be the basis for levy of penalty - Held that:- Penalty proceedings are different from assessment proceedings as held in the case of Anantharam Veerasinghaiah & ......
2011 (7) TMI 534 - ITAT CHENNAI
Rane (Madras) Ltd. Versus Income-tax Officer, Company Circle-V(3), Chennai
Disallowance u/s 40(a)(i) - payments of export commission to M/s. Al Aquilli Trading L.L.C., Dubai and Mr. James Drutchas, U.S.A. as Consultants/representatives - Miscellaneous application filed - Held that:- Perusal of the miscellaneous application ......
2011 (7) TMI 522 - Bombay High Court
Director of Income Tax Versus Gartner Ireland Ltd.
Penalty u/s 271(1)(c) - AO taxed the royalty income - CIT(Appeals) deleted the penalty on the ground that the assessment has been made on the basis of the facts disclosed by the assessee - Revenue informs the Court that the Revenue has filed an appea ......
2011 (7) TMI 392 - ITAT MUMBAI
Nippon Kaiji Kyokoi Versus Income-tax Officer, International Taxation, Ward-3(1)
Whether or not the Commissioner (Appeals) was justified in holding that only 10% of the fee received by the Head Office for services rendered in India through independent surveyors is attributable to PE ignoring the facts that such services are not e ......
2011 (7) TMI 104 - AUTHORITY FOR ADVANCE RULINGS
WesternGeco International Limited.
Applicability of section 44BB - Royalty or fees for technical services - It is engaged in the business of acquisition and processing of 2D and 3D seismic data for companies engaged in the exploration and production of mineral oils in India - if the i ......
2011 (7) TMI 103 - AUTHORITY FOR ADVANCE RULINGS
Siem Offshore Inc. Versus Commissioner concerned Director of Income-tax,
DTAA between India and Norway - Applicability of section 44BB - Royalty or fees for technical service - The consortium agreement between the applicant and the others was recognized by ONGC since the payments were to be made direct by ONGC to the appl ......
2011 (7) TMI 99 - AUTHORITY FOR ADVANCE RULINGS
Deepak Cables (India) Limited
Advance ruling - Consortium agreement - Application u/s 245R(2) - Taxability of the off-shore sales by LS Cables to the applicant - Applicant transfer the goods by LS Cables, Korea to the applicant being outside India, there is no territorial nexus f ......
2011 (7) TMI 98 - AUTHORITY FOR ADVANCE RULINGS
LS Cable Limited Versus Korea Commissioner Concerned Director of Income-tax-I
Tax liability - Agreement for Avoidance of Double Taxation between India and Korea - The applicant is a company incorporated and located in Korea - applicant entered into three separate contracts with DTL - Nothing in law prevents the parties to ente ......
2011 (7) TMI 95 - ITAT, MUMBAI
Additional Director of Income-tax (International Taxation), Circle 2(1), Mumbai Versus Star Cruise India Travel Services (P.) Ltd.
Assessee in default - TDS u/s 195 - whether or not the Star Cruise Management Limited was liable to income-tax in India in respect of the payments received it by through this assessee - The source rule of taxation, which typically originates in domes ......
2011 (7) TMI 60 - BOMBAY HIGH COURT
Aditya Birla Nuvo Limited, & others Versus The Deputy Director of Incometax, & others
Relief - International taxation - Capital gain - on transfer of shares of Idea Cellular Limited in favour of Indian Rayon under Sale and Purchase Agreement dated 28th September, 2005 - in the present case genuineness of the transaction were considere ......
2011 (7) TMI 51 - AUTHORITY FOR ADVANCE RULINGS
Bourbon Offshore Asia Pte. Ltd Versus Commissioner concerned Director of Income-tax
Applicability of section 44BB - Whether on the stated facts and in law the income derived by BOA ought to be computed in accordance with the computation mechanism under section 44BB of the Act - There is no dispute that the applicant is engaged in th ......
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