2014 (3) TMI 254 - ITAT MUMBAI
M/s. Johnson & Johnson Ltd. Versus The ACIT, LTU, Mumbai
Disallowance of tax on Brand Usage Royalty Held that:- The decision in Johnson & Johnson Ltd. Versus Assistant Commissioner of Income-tax [2014 (2) TMI 978 - ITAT MUMBAI] followed - The CIT(A) erred in ignoring the copy of draft brand usage royalty ......
2014 (3) TMI 106 - ITAT HYDERABAD
Sanofi Pasteur Merieux (Formerly known as Shanh SAS.) France Versus Dy. Commissioner of Income Tax
Withholding TDS u/s 195 of the Act - Gross sale consideration paid to foreign nationals Assessee in default u/s 201(1) of the Act - Held that:- The reason for fastening the obligation to deduct tax at source of the payment to non-resident is only i ......
2014 (3) TMI 100 - ITAT DELHI
DCIT, Circle 12(1), New Delhi Versus M/s. Hero Management Services Ltd.
Deletion of disallowance Failure to deduct TDS on market development expenses Held that:- The decision in Asstt. Commissioner of Income Tax Versus M/s. Hero Management Services Ltd., M/s. Hero Corporate Services Ltd. [2013 (5) TMI 730 - ITAT DELH ......
2014 (2) TMI 1112 - ITAT HYDERABAD
M/s. IIC Systems Pvt. Ltd, Hyderabad Versus ACIT, Circle 2(1) Hyderabad
Inflated expenditure Held that:- The AO and CIT(A) erred in resorting to mathematical jugglery so as to deny the expenditure claimed by the assessee - There is no basis for AO disallowance of the so called inflated expenditure and CIT(A) also did n ......
2014 (2) TMI 981 - ITAT HYDERABAD
M/s. Aurobindo Pharma Limited Versus Addl. CIT, Range-1, Hyderabad
Transfer pricing adjustment Interest received on loans given to Associated enterprises Held that:- The decision in Siva Industries & Holdings Ltd. Versus Assistant Commissioner of Income-tax, Co. Circle VI(4), Chennai [2012 (10) TMI 890 - ITAT CH ......
2014 (2) TMI 933 - ITAT PUNE
Deepak Fertilizers and Petrochemicals Corporation Limited Versus DDIT, (Int. Tax) -I, Pune
Whether the amount paid for acquisition of Process Design Documentation is fee for technical services - assessee had pleaded that the impugned portion of the consideration is for the supply of drawings, designs and detailed engineering services for t ......
2014 (2) TMI 902 - AUTHORITY FOR ADVANCE RULINGS
Endemol India Private Limited Mumbai Versus Commissioner of Income-tax-XI, Mumbai
Nature of services provided - Existence of Permanent Establishment DTAA between India and Brazil - Held that:- The services provided by the non-resident companies to the applicant company are line production services it is been held in the applic ......
2014 (2) TMI 802 - AUTHORITY FOR ADVANCE RULINGS
Re: Booz & Company (Australia) Pvt. Ltd.
Permanent Establishment Chargeability of payments received u/s 9(1)(vii) r.w section 115A and 44DA of the Act - Whether the payments received/receivable in connection with the provision of services of technical/professional personnel to Booz India ......
2014 (2) TMI 736 - ITAT MUMBAI
Antwerp Diamond Bank NV Versus Additional Director of Income-tax (International Taxation)
Disallowance for payment made to the Head Office Held that:- The certificate issued by Ernest and Young had been issued for the information of and assistance to the Banks management in connection with the review by local tax authorities - It was ......
2014 (2) TMI 653 - ITAT AGRA
Deputy Commissioner of Income Tax Versus Virola International
Deletion of disallowance u/s 40(a)(ia) of the Act - Foreign remittances made for design and development expenses TDS not deducted u/s 195 r.w.s. 9(1)(vii) of the Act Held that:- The decision in Ishikawajima Harima Heavy Industries Ltd Vs DIT [20 ......
2014 (2) TMI 554 - ITAT AGRA
Deputy Commissioner of Income Tax Versus Gupta Overseas
Invocation of Rule 27 f the Appellate Tribunal Rules, 1963 right of the assessee in appeal before Tribunal - Held that:- it is not right to suggest that when an assessee is not in cross appeal or cross objection, it is not permissible for the asses ......
2014 (2) TMI 434 - MADRAS HIGH COURT
M/s. Anand Transport (Private) Ltd. Versus Assistant Commissioner of Income Tax
Requirement to deduct tax Permanent Establishment DTAA between India and Singapore Applicability of Section 44B of the Act Held that:- The income arising out of the transaction between the assessee and non-resident company, is taxable in Sin ......
2014 (2) TMI 235 - ITAT MUMBAI
Income Tax Officer (International Taxation) Versus M/s Pipavav Shipyard Ltd.
Assessee in default u/s 201 Non-deduction of TDS on consultancy work Penalty u/s 201(1A) of the Act Held that:- The actual payment of the amount was dependent on certain regulatory compliances and approvals which were ultimately not received - T ......
2014 (2) TMI 138 - ITAT HYDERABAD
Asst. Commissioner of Income-tax Versus Madhucon Sino Hydro(JV)
Liability to deduct TDS Payments made to constituent partners Held that:- The Assessing officer erred in recasting the P&L of the AOP to bring in the works directly taken up by the constituents - the constituents have offered the income from thei ......
2014 (1) TMI 1405 - DELHI HIGH COURT
Director of Income Tax Versus TV Today Network Ltd.
Whether amount paid is liable for tax deduction at source - Held that:- Decision in Asia Satellite Telecommunications Co. Ltd. v. DIT [2011 (1) TMI 47 - DELHI HIGH COURT] followed - The payments made for providing data transmission services through p ......