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Income Tax Case Laws - Section: 9


Income Tax

Cases for Section: 9
Showing 361 to 375 of 868 Records

2011 (11) TMI 439 - Bombay High Court

DIT Versus Xelo Pty. Ltd.

Taxability of the amounts received by the assessee on account of offshore supplies - single contract for supply of equipments and services offshore/onshore - Held That:- If the composite contract specifically records the quantum of goods to be suppli ......

2011 (11) TMI 300 - ITAT MUMBAI

WSA Shipping (Bombay) (P.) Ltd. Versus ADIT (IT), Cir 2(2)

Agent of Non Resident - Business Connection - Payments made to Non residents without deducting TDS - DTAA between India and Singapore - Held that:- The business of the non-resident was transhipment of cargo and the appellant engaged their services fo ......

2011 (11) TMI 132 - ITAT MUMBAI

Novel Inc. Versus Deputy Director of Income-tax (International Taxation) - 4(2), Mumbai

Sale of Software - Business profit or Royalty - Article 5 of the India - USA treaty - assessee sold software product to NIPL - Neither NIPL nor its end users were permitted to copy the same and exploit such products for commercial purposes. The custo ......


Groupe Industrial Marcel Dassault, Versus Merieux Alliance

DTAA with French Republic - whether the Capital gains arising from the sale of shares of ShanH (French incorporated Entity) by the Applicant (French Incorporated Entity) to Sanofi (French Incorporated Entity) is liable to tax in France or in India - ......

2011 (11) TMI 23 - ITAT MUMBAI

Asstt. Director of Income-tax, (International Taxation), 4(2) Versus Neo Sports Broadcast (P.) Ltd.

TDS on Royalty 195- Broadcasting of cricket matches - live feed or recorded feed - Royalty defined in DTC Bill, 2010 - DDIT has held that income can be held as accruing or arising to Nimbus directly or indirectly through or from any business conn ......

2011 (11) TMI 20 - DELHI HIGH COURT

The Commissioner of Income Tax Delhi-IV, New Delhi Versus EON Technology P. Limited

Addition u/s 40(a)(i) - TDS on commission income - business connection - Income of non resident - Income deemed to accrue or arise in India - Circular No.23 dated 23.07.1969 - Revenue contended that the commission income of Rs.33,36,068/- earned b ......

2011 (10) TMI 239 - Karnataka High court

Commissioner of Income-tax, International Taxation Versus Sunray Computers (P.) Ltd.

Income deemed to accrue or arise in India - Assessee imported software from USA - AO raised query for faliure to deduct TDS on payment - Assessee also entered into contract with Telecom department for execution of foreign agreement - Held that:- Ev ......

2011 (10) TMI 238 - ITAT MUMBAI

Vinbros & Co. Versus Assistant Commissioner of Income-tax, Circle I, Pondicherry

Deduction u/s 80-IB - in view of decision in the case of Liberty India v. CIT (2009 - TMI - 34471 - SUPREME COURT)- Duty draw back, cash assistance and income of the like are not eligible for deduction. Tax Deduction at Source - nature of p ......


Commissioner of Income-tax Versus Samsung Electronics Co. Ltd. & Others

Royalty paid to foreign software Supplier- deduction of tax at source- Double Tax Avoidance Agreement- Held that:- Assessee imported software products from USA, France and Sweden. No tax was deducted at source in respect of such payments on the groun ......

2011 (9) TMI 807 - ITAT DELHI

Nimbus Sport International Pte. Ltd. Versus Deputy Director of Income-tax, Circle-2(2), International taxation, New Delhi

India Singapore DTAA - assessee company, tax resident of Singapore, entered into an agreement with Prasar Bharti[PB] for the telecasting production of cricket events held during stipulated period - whether receipts from Prasar Bharti amount to busine ......

2011 (9) TMI 754 - ITAT DELHI

Guy Carpenter & Co. Ltd. Versus Additional Director of Income-tax, Circle 1(2), International Taxation, New Delhi

DTAA between India and UK - Whether reinsurance brokerage/ commission is a Fees for technical services - it is clear that Article 13(4) emphasis on rendering any technical or consultancy services, which are ancillary and subsidiary to the application ......

2011 (9) TMI 482 - DELHI HIGH COURT


Income deemed to accrue or arise in India - Foreign Co. engaged in the business of manufacture and sale of power transmission cable and related equipments entered into off-shore supply and on-shore erection testing, commissioning, etc. of Fiber Opti ......

2011 (9) TMI 207 - ITAT, CHENNAI

M/s Dassault Systems Simulia P. Ltd [Earlier known as Abaqus Engineering Pvt. Ltd.] Versus Dy. CIT

Withholding tax u/s 195 - Royalty u/s 9(1)(iv) - right to use the licensed version of the software - Disallowance u/s 40(a)(i) for non deduction of TDS - CIT(A) observed that:- when the payer has a bona fide belief that the income is not chargeable t ......


Millennium IT Software Ltd., Versus Commissioner concerned The Director of Income-tax (International Taxation), Mumbai.

DTAA with Sri Lanka - Implementation fee and ‗Licence and Maintenance fee - No PE - TDS u/s 195 - it is clear that the license to use computer Program means right to use the intellectual property that is the copyright in the computer program in ......

2011 (8) TMI 769 - DELHI HIGH COURT

Rolls Royce Singapore (P.) Ltd. Versus Assistant Director of Income-tax

Permanent Establishment(PE) - Dependent agent - Whether in the facts and circumstances of the case, the ITAT grossly erred in holding that ANR should be regarded as a Dependent Agent Permanent Establishment of the Appellant under the Article 5(8) of ......



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