2014 (4) TMI 569 - ITAT HYDERABAD
Asst. Director of Income-tax (International Taxation) Versus M/s Bartronics India Ltd.
Applicability of section 9 of the Act Royalty for technical services Supply of software on license Article 12 of Indo-Singapore Treaty Liability to deduct TDS u/s 195 of the Act - Held that:- Relying upon Motorola Inc. Versus Deputy Commissio ......
2014 (4) TMI 284 - ITAT MUMBAI
Tata Motors Limited Versus Income Tax Officer (IT) (TDS)
Entitlement for interest u/s 244A of the Act Refund of taxes (TDS) deposited in excess order passed u/s 195 of the Act Held that:- The language used in section 244A, clearly provides that interest has to be granted on the refund of any amount w ......
2014 (4) TMI 277 - ANDHRA PRADESH HIGH COURT
Sriram Refregeration Industries Versus Income-tax Officer
Scope of salary for the purpose of TDS Conveyance allowance - Whether conveyance allowance is given for coming from house to office/factory and back instead of providing a vehicle for transportation is liable to be treated as salary for the purpose ......
2014 (4) TMI 273 - ITAT DELHI
M/s Alcatel-Lucent France (formerly known as Alcatel CIT, France), C/o Pricewaterhouse Coopers Versus Assistant Director of Income Tax, International Taxation
Admission of additional evidence Reduction in quantum of revenue - Exclusion of sales from revenue Held that:- When the AO was not satisfied with the assessees estimate, he should have allowed at least one more opportunity to the assessee intima ......
2014 (4) TMI 249 - AUTHORITY FOR ADVANCE RULINGS
Endemol India Private Limited Mumbai Versus Commissioner Concerned : Commisioner of Income-tax-XI, Mumbai
Nature of Expenses Fees for technical services or not Article 12 of DTAA between India and Netherlands - Whether the payments made by the applicant to Endemol Holding for availing routing administrative services under the terms of the Consultancy ......
2014 (4) TMI 160 - ITAT HYDERABAD
ADIT (International Taxation-I), Hyderabad Versus M/s. DQ Entertainment (International) P. Ltd.
Withholding Tax (TDS) u/s 195 - FTS u/s 9(1)(vii) - Levy of demand u/s 201 and 201(1A) of the Act Payments made to foreign companies Held that:- The payments received by it from foreign clients for exactly the similar work executed by it have not ......
2014 (4) TMI 68 - ITAT MUMBAI
M/s. New Bombay Park Hotel Pvt. Ltd. Versus Income Tax Officer(International Taxation)
Default for non-deduction of TDS - additions u/s 40(a)(i) - Indo-UK DTAA - Deemed income u/s 9(1)vi)/(vii) Assessee in Default u/s 201 for Non-Deduction of tax at Source - assessee did not deduct tax with regard to two phases on the ground that t ......
2014 (3) TMI 892 - ITAT HYDERABAD
Dy. Commissioner of Income-tax Versus M/s. Agarwal Industries Ltd.
Addition u/s 40(a)(ia) of the Act - TDS on interest paid for delayed payment of purchase consideration to raw material suppliers located in Singapore and Malaysia - Details of interest portion contained in purchase invoice not considered Held that: ......
2014 (3) TMI 610 - SUPREME COURT
Union of India Through Director of Income Tax Versus M/s Tata Chemicals Ltd.
Payment of interest on refund u/s 244A - refund of excess tax deposited u/s 195(2) - Whether the revenue is legally responsible u/s 244A of the Act for payment of interest on the refund of tax made to the resident/deductor u/s 240 of the Act - Whethe ......
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 ......