2014 (7) TMI 765 - ITAT MUMBAI
Deputy Director of Income-tax Versus IATA BSP India
Nature of payment made for BSP link services rendered by ADP-GSI France Requirement to deduct TDS on fees paid to technical services Held that:- The payment made to ADP-GSI France for providing BSP link services to the Agents/Air lines was treate ......
2014 (7) TMI 761 - ITAT CHENNAI
The Income Tax Officer Versus M/s. Gadsyl Exports P. Ltd.
Non-deduction of TDS on overseas payment of agency commission Disallowance u/s 40(a)(ia) of the Act Held that:- Assessee is availing the services of non-resident agents for procuring export orders for which commission is paid - nonresident agents ......
2014 (7) TMI 418 - ITAT MUMBAI
The Asst. Commissioner of Income Tax Versus Raj Girish Karia
Disallowance of Freight and insurance charges paid to Shipping Companies u/s 40(a)(ia) - TDS u/s 194C / 195 Held that:- The assessee has to show that the shipping companies to whom payments were made are not only non-residents, but also he has to s ......
2014 (7) TMI 265 - BOMBAY HIGH COURT
Director of Income Tax (International Taxation) Versus M/s. Mahindra & Mahindra Limited
Period of limitation for declaring Assessee in default - time limit for proceedings u/s 201(1) and (1A) of the Act - Reassessment u/s 147 of the Act tribunal held that the order passed under Section 195 r/w 201(1) or 201(1A) of the Income Tax Act, ......
2014 (7) TMI 255 - ITAT CHENNAI
The Asst. Commissioner of Income Tax Versus M/s. Myrind School of Catering & Computer Management (P) Ltd.
Addition u/s 40(a)(ia) Payment to overseas institution as fees for awarding the degrees, supplying books and course material TDS not deducted u/s 195 - technical know-how or technical services - Held that:- CIT(A) rightly of the view that the amou ......
2014 (6) TMI 837 - ITAT DELHI
ITO, Ward 12(4), New Delhi Versus M/s. Himalya International Ltd.
Deletion of disallowance of USA expenses - non deduction of TDS on remittance to non-resident - reimbursement of expenses - Held that:- Following Himalya International Ltd. Versus DCIT Circle-12(1), New Delhi and ITO, Ward-12(4), New Delhi Versus Him ......
2014 (6) TMI 707 - ITAT CHENNAI
Income Tax Officer (TDS) Versus M/s. Cognizant Technology Solutions India Pvt. Ltd. And Others
Royalty u/s 9(1)(vi) - TDS u/s 195 hiring of International Private Leased Circuits [IPLC] - Nature of Remittance made to Non-resident Company Whether the services provided by the overseas company constitutes Royalty or not - Held that:- Followi ......
2014 (6) TMI 643 - ITAT CHENNAI
The Assistant Commissioner of Income Tax Versus M/s. T. Abdul Wahid Tanneries Pvt. Limited
Disallowance u/s 40(a)(i) of the Act Non-deduction of TDS u/s 195 Held that:- No evidence has been placed on record to allege any misreading of evidence by the CIT(A) - assessees overseas agents do not have any permanent establishment in India ......
2014 (6) TMI 463 - ITAT CHENNAI
Commissioner of Income Tax Versus M/s. T. Abdul Wahid & Company, M/s. Farida Leather Company
Deletion of disallowance u/s 40(a)(ia) of the Act TDS not deducted - Payment made to foreign commission agents Held that:- Following Income-tax Officer, Co. Ward-II(1) Versus Faizan Shoes (P.) Ltd. [2014 (1) TMI 440 - ITAT CHENNAI] sales commis ......
2014 (6) TMI 290 - ALLAHABAD HIGH COURT
Commisisoner Of Income Tax (Central) Versus M/s Model Exims
Deletion of disallowance of Non-deduction of tax u/s 195 of the Act Retrospective effect of section 9 (1) (vii), read alongwith the explanation introduced by Finance Act, 2010 w.e.f. 1.6.1976 of the Act Disallowance of payment u/s 40(a)(ia) of th ......
2014 (6) TMI 255 - ITAT MUMBAI
Asst. Commissioner of Income Tax Versus Rapid Pack Engg (P) Ltd.
Deletion of addition u/s 40(a)(ia) of the Act - Commission paid to Non-residents Applicability of benefit of circular - CIT(A) not appreciated the fact that Circular No. 786 has been withdrawn by the Circular No. 7 of 2009 dated 22.10.2009 Availa ......
2014 (5) TMI 744 - ITAT AHMEDABAD
Larsen & Toubro Limited L&T Technology Centre Versus The ITO (International Tax), Baroda
Non-speaking order - Assessee in default u/s 201(1) of the Act or not Payment of income chargeable to tax not made Requirement to deduct TDS u/s 195 of the Act Purchase of software Scope of term Royalty u/s 9(1)(vi) of the Act Held that:- A ......
2014 (5) TMI 738 - ITAT HYDERABAD
M/s. IVAX Paper Chemicals Ltd., Hyderabad Versus V/s. Addl. Commissioner of Income-tax, Hyderabad
Disallowance u/s 40(a)(ia) of the Act Sales commission paid to foreign agent Applicability fo section 195 of the Act - Held that:- There cannot be any dispute with regard to the services rendered by the foreign party - The commission bill of M/s. ......
2014 (5) TMI 631 - AUTHORITY FOR ADVANCE RULINGS
In re: Pan-Asia iGATE Solutions
Withholding of Tax u/s 195 of the Act Purchase of equity shares LTCG arising u/s 112(1) of the Act Whether the tax is required to be withheld by the Applicant u/s 195 of the Act on purchase of equity shares of Patni Computer Systems Ltd, being ......
2014 (5) TMI 629 - AUTHORITY FOR ADVANCE RULINGS
In re: Steria (India) Limited
Payment made for management services DTAA between India and France - the term "make available" is not figuring in the treaty - Whether the payment made by Steria for the management services provided by Groupe Steria SCA will not be taxable in India ......