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 ......
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 ......
2011 (5) TMI 588 - ITAT, MUMBAI
Deputy Commissioner of Income-tax-3(2) Versus Navinon Ltd.
Notional interest on deposit - India USA DTAA - Held that:- CIT(A) in assessment years 1993-94 to 1999-2000 stated that when the recovery of principal amounts itself is doubtful to be realized from the debtors, there is no justification to contemplat ......
2011 (5) TMI 586 - ITAT, MUMBAI
Atos Origin IT Services Singapore Pte. Ltd. Versus Assistant Director of Income-tax-(Intl. Taxation) 1(1), Mumbai
India and Singapore DTAA - Royalty payment - amount received by assessee from SCB India for use of disc space in the hardware of the assessee at its data centre in Singapore - Held that:-
In this case, the assessee did not have the right to access ......
2011 (5) TMI 580 - ITAT, Mumbai
Standard Chartered Bank Versus DDIT
India Singapore DTAA - data processing charges to Singapore company SPL treated as Royalty - liability to pay tax in India and subject to withholding tax at 15% under Article 12(3)(a) of DTAA - assessee contested on no "Permanent Establishment" of SP ......
2011 (5) TMI 577 - ITAT, Mumbai
Six Continents Hotels Inc. Versus DCIT
DTAA - Fee for Included Services(FIS) - License fees of trademark - ssessee maintains a separate fund wherein it receives the marketing and reservation contribution from the hotels worldwide (including hotels in India) - the identical issue of tax ......
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