2014 (11) TMI 552 - ITAT AHMEDABAD
FAG Bearings India Ltd. Versus DCIT, Ci rcle-1, Baroda
Addition of interest received on income tax refund Held that:- As decided in assessees own case for the earlier assessment year, the decision in Avada Trading Co. (P.) Ltd. Versus Assistant Commissioner of Income-tax, Spl. Circle 18(1) [2006 (1) T ......
2014 (11) TMI 404 - ITAT HYDERABAD
Dr. Reddys Research Foundation, Hyderabad Versus The DCIT, Circle 14(3), Hyderabad
Fees for technical services Indo-US DTAA - payment made to Netherlands Company M/s. NDDO Oncology BV for conducting pre-clinical research studies - Whether the payments are to be treated as fees for technical services under Article 12 of the DTAA o ......
2014 (11) TMI 318 - DELHI HIGH COURT
Commissioner of Income Tax-IV Versus M/s. Himalya International Ltd.
TDS not deducted on payments - Partial additions sustained Bills and invoices could not be produced Held that:- Section 40(a)(ia) was neither invoked by the AO nor by the first appellate authority - before the Tribunal, revenue did raise the cont ......
2014 (11) TMI 275 - ITAT COCHIN
The Deputy Commissioner of Income-tax Versus M/s. Transformers & Electricals Kerala Ltd.
Allowbility of the claim u/s. 40(a)(ia) r.w.s. 9(1) - Payment of sales commission made to the selling agents without deduction of TDS Held that:- The disallowance shall be made in case of any payment made which is chargeable under this Act and is p ......
2014 (11) TMI 44 - ITAT HYDERABAD
M/s. AMD Research & Development Center India Private Limited Versus Dy. Commissioner of Income-tax, Circle 1(2), Hyderabad
TDS u/s 195 - Nature of amount paid to parent company abroad on account of software expenses and engineering expenses - reimbursement of expenses or not - Whether the assessee company can be treated as an assessee in default u/s 201(1) - AO observed ......
2014 (10) TMI 748 - RAJASTHAN HIGH COURT
Commissioner of Income Tax Versus M/s. Modern Insulators Ltd.
Payment of commission to non-resident agents Liability to deduct TDS Question of law not challenged before Tribunal - Held that:- The question of deduction of tax at source under Section 195 would arise only if the payment of commission to a non- ......
2014 (10) TMI 463 - ITAT CHENNAI
Financial Software & Systems (P.) Ltd. Versus Deputy Commissioner of Income-tax/Assistant Commissioner of Income-tax, Company Circle II (1), Chennai
Validity of reopening of assessment Change of opinion - TDS deduction on payment to Non-resident companies - Held that:- The returns filed by the assessee company for the AYs 2003-04 and 2005-06 were processed under sec.143(1) - Obviously, there is ......
2014 (10) TMI 212 - ITAT DELHI
Agence France Presse, C/o. Vishwanath Singh & Associates Versus ADIT, Circle 1(1), International Taxation, New Delhi
Application for admission of additional evidence - whether the application for admission of additional evidence dated 13.06.2014 as filed by the revenue before us in terms of Rule 29 of the ITAT Rules, 1963, should be allowable or not Held that:- T ......
2014 (10) TMI 37 - DELHI HIGH COURT
Bernstein Litowitz Berger And Grossmann LLP And Others Versus Union of India And Others
Claim of damages on fraud Advance ruling with regard to transfer of funds from India to US - Whether the amount of the settlement funds which had been transferred from India to USA were chargeable to tax in India - Held that:- The Authority for Ad ......
2014 (10) TMI 32 - ITAT MUMBAI
Deputy Director of Income-tax (International Taxation) 2(1) Versus Videsh Sanchar Nigam Ltd.
Assessee in default u/s 201(1)/201(1A) r.w.s. 195 Failure of TDS Period of limitation - Payment made to Lead Managers/Managers with the services rendered for GDR issue Held that:- Following the decision in Mahindra And Mahindra Limited. Versus ......
2014 (10) TMI 3 - ANDHRA PRADESH HIGH COURT
Shakti LPG Ltd., Hyderabad Versus Income Tax Officer, Ward-8, (TDS), Hyderabad
Assessee in default u/s 201 TDS deduction Held that:- The deduction of tax at source is one of the important features of the Act - In a way, it obviates the necessity for the department to track the amount paid by an assessee to another, and then ......
2014 (9) TMI 889 - HIGH COURT OF KARNATAKA
Commissioner of Income-tax Versus CGI Information Systems & Management Consultants (P.) Ltd.
Liability to deduct TDS u/s 195(1) Remittances made to Non-resident Article 12 of Indo-Canada DTAA - cost sharing agreement and payments were made by the assesee for reimbursement of cost/expenses - Whether the Tribunal was correct in holding th ......
2014 (9) TMI 352 - ITAT AHMEDABAD
The ITO (Intl. Taxn) -II, Ahmedabad Versus Adani Port- Infrastructure Pvt. Ltd. and Dholera Port Ltd.,
Fees for technical services remitted to non-resident Applicability of Article 13(c) Indo-UK DTAA Effect of Explanation to section 9(1)(vii) w.e.f. 1.6.1976 Held that:- In the case of Diamond Services International (P.) Ltd. v. Union of India [2 ......
2014 (9) TMI 312 - ITAT DELHI
Right Tunnelling Co. Ltd. Versus ADIT Circle-2(1), (International Taxation), New Delhi
Expenses incurred by HO in Thailand for Indian Project Held that:- AO was of the view that the expenses are initial startup expenses and are in the capital field AO as well as the CIT(A) have not stated that the expenditure claimed have no nexus ......
2014 (9) TMI 268 - ITAT CHENNAI
Deputy Commissioner of Income-tax Versus M/s. Farida Prime Tannery Pvt. Ltd. And Others
Non-deduction of TDS on agency / sales commission payments made to non-resident agents Invocation of section 40(a)(i) r.w. section 195 Held that:- Following the decision in GE India Technology Centre Private Ltd. Versus Commissioner of Income Tax ......