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Income Tax Case Laws - Section: 9


Income Tax

Cases for Section: 9
Showing 361 to 375 of 848 Records


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 ......


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 ......


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 ......


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 ......


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 ......


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 ......


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 ......

2011 (6) TMI 329 - ITAT MUMBAI

Ingram Micro (India) Exports Pte. Ltd. Versus Assistant Commissioner of Income-tax (International Taxation), 3(1), Mumbai

Reopening of assessment - as per AO assessee company was conducting its business operations in India through TPIL and it had a permanent establishment (PE) in India - Held that:- In the present case, there was no basis for the Assessing Officer to ha ......

2011 (6) TMI 145 - ITAT, MUMBAI

Assistant Director of Income-tax (International Taxation) 1(1) Versus ACM Shipping India Ltd.

DTAA - TDS u/s 195 - fees for technical services (FTS) - No Permanent Establishment (PE) - Circular No. 7 of 2009, dated 22-10-2009 - An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracti ......

2011 (6) TMI 60 - ITAT, MUMBAI

Assistant Commissioner of Income-tax 11(1), Mumbai Versus Mansih Dutt

Allowance - Deduction under section 40(a)(ia) - 25 per cent of the royalty paid - TDS under section 194J - the payment in question was made by the assessee for obtaining certain rights over the film Boa and Passion. The rights acquired by the assesse ......



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