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Income Tax Case Laws - Section: 9

 

Income Tax

Cases for Section: 9

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Showing 361 to 375 of 883 Records
 

2012 (2) TMI 258 - AUTHORITY FOR ADVANCE RULINGS

Citrix Systems Asia Pacific Pty. Limited,

DTAA with Australia Australian company entered into distribution agreement with Indian Company(IMI Ltd) for the distribution and sale of its software and hardware products in India - sale and collection of software product is made through the distr ......

2012 (2) TMI 173 - AUTHORITY FOR ADVANCE RULINGS

AREVA T&D India Ltd., In re

Indo-French DTAA French Company entered into an IT Agreement with the applicant to provide support services in the area of IT - whether royalty or FTS whether payment would fall under the provisions of Article 13 of the Indo France DTAA in view o ......

2012 (2) TMI 98 - AUTHORITY FOR ADVANCE RULINGS

Shell India Markets (P.) Ltd., In re

Double Taxation Avoidance Convention between India and UK Cost Contribution Agreement ("CCA") with SIPCL (company incorporated in UK) for availing General Business Support Services (General BSS) - determination of nature of payments made to SIPCL a ......

2012 (2) TMI 75 - AUTHORITY FOR ADVANCE RULINGS

CTCI Overseas Corpn. Ltd., In re

Off-shore supplies & services - applicant being Hong Kong company project awarded by Petronet - consortium formed with an Indian company(CINDA), to execute the project - CTCI responsible for off-shore supplies & services & CINDA for onshore supplie ......

2012 (2) TMI 74 - AUTHORITY FOR ADVANCE RULINGS

SEPCO III Electric Power Construction Corporation, In re

Off- shore supply contract India-China Double Taxation Avoidance Convention - applicant being company of China contract for supply of equipment to Indian company - Indian company, defined as the owner in the contract - passing of the title to t ......

2012 (1) TMI 52 - SUPREME COURT OF INDIA

Vodafone International Holdings BV. Versus Union of India & Anr.

Scope of total income - Revenue seeks to tax the capital gains arising from the sale of the share capital of CGP on the basis that CGP, whilst not a tax resident in India, holds the underlying Indian assets. - Held that:- Applying the look at test in ......

2012 (1) TMI 5 - DELHI HIGH COURT

DIRECTOR OF INCOME TAX Versus RIO TINTO TECHNICAL SERVICES

DTAA with AUSTRALIA Fees for technical services (FTS) or inclusive contracts of technical nature - applicability of Articles 7 or 12 of the DTAA assessee having PE in India whether income to be construed as business income or gross receipts ......

2011 (12) TMI 195 - ITAT MUMBAI

ADIT (International Taxation) -2(2) Versus Warner Brother Pictures Inc.

Royalty for exclusive rights of distribution of Cinematographic films India-USA Treaty assessee is a non-resident company having no PE in India agreement with Warner Bros Pictures (India) Pvt. Ltd(WBPIPL) for grant of rights WBPIPL deducted tax ......

2011 (12) TMI 91 - Delhi High Court

Director of Income-tax Versus Ericsson AB & Ericsson Radio System AB & Metapath Software International Ltd.

Foreign company engaged in supply of hardware and software which is used in the business of rendering telecommunication services validity of notice issued u/s 142 - viability of charging of interest u/s 234A and 234B on the ground that the reven ......

2011 (12) TMI 78 - AUTHORITY FOR ADVANCE RULINGS

Shell Technology India (P.) Ltd., In re

Fees for technical services - Double Taxation Avoidance Convention (DTAC) between India and Netherlands - payment made to SSSABV for business support services. - The services include invoice processing, monitoring operational execution, SOX (Business ......

2011 (12) TMI 17 - AUTHORITY FOR ADVANCE RULINGS

Perfetti Van Melle Holding BV., In re

Double taxation Agreements - Meaning of fees for technical services (FTS) - allocation of cost - the Applicant will incur cost in providing various operational and other support services for the benefit of group companies by drawing its own resources ......

2011 (11) TMI 507 - ITAT MUMBAI

Mahindra & Mahindra Ltd. Versus Assistant Director of Income-tax (IT) Range-1

Fees for technical services - reimbursements of expenses incurred for conducting market research to non resident deemed as fees for technical services liability of TDS assessee treated as agent of non- resident - Held that:- There was only a refe ......

2011 (11) TMI 505 - ITAT MUMBAI

International Global Networks BV Versus Deputy Director of Income-tax (International Taxation) -3(1), Mumbai

India Netherland DTAA - Taxing of interest income on income-tax refund - @ 41% OR 10% as per assessee under Article 11 of DTAA - Held that:- As decided in ACIT v. Clough Engg. Ltd. [2011 (5) TMI 562 - ITAT, DELHI] & Hapag Lloyd Container Linie GmbH v ......

2011 (11) TMI 484 - ITAT MUMBAI

Joint Director of Income-tax-OSD(IT)3(1) Versus Harvard Medical International, USA

India USA DTTA services rendered in relation to health care - determination of nature of fees and its taxability received from Wockhardt Hospital Ltd(WHL) and MAX India Ltd(MAX) Royalty or Fees for Included Services(FIS) or Business Profits - Hel ......

2011 (11) TMI 483 - ITAT MUMBAI

De Beers UK Ltd. Versus Deputy Commissioner of Income-tax (Intl. Taxation) -1(2)

Marketing contributions - assessee company who is incorporated as tax resident of UK - assessee contested against as it did not relate to AY 2007-08 - Held that:- It is required to be seen whether the amount in question was payment received by assess ......

 
   
 
 
 

 

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