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Income Tax Case Laws - Section: 9


Income Tax

Cases for Section: 9
Showing 321 to 335 of 868 Records

2012 (5) TMI 124 - ITAT Mumbai

Armayesh Global Versus Assistant Commissioner of Income-tax-12(3)

Payment to Overseas Commission agent - whether it is simply commission, or it is in the nature of "fees for technical services"? - liability on the assessee to deduct withholding tax Held that:- The agreement between the assessee and the Non Resid ......

2012 (5) TMI 99 - DELHI HIGH COURT


Reopening assessment - petitioner contested that he is a non-resident and had no income chargeable to tax in India other than what was declared - Held that:- No merit in the writ petition - the affidavit filed by department affirmed that he had init ......

2012 (5) TMI 42 - DELHI HIGH COURT


Profit in lieu of salary for services rendered outside India - ITAT deleted the addition made by the AO Held that:- Payment in question was received towards retirement benefit/severance/vacation engagement from the erstwhile employer on termination ......

2012 (5) TMI 31 - DELHI HIGH COURT

Director of Income-tax Versus Guy Carpenter & Co. Ltd.

India U.K. DTAA - Reinsurance brokerage/commission with international re-insurance companies Revenue treated it within the definition of fees for technical services u/s 9(1)(vii) r.w Article 13 of the India U.K. DTAA - Held that:- The assessee comp ......

2012 (4) TMI 354 - ITAT AHMEDABAD

AIA Engineering Ltd. Versus Additional Commissioner of Income-tax, Range-I, Ahmedabad

Treating the Appellants wholly owned subsidiary in UAE as its proprietary concern and treating income earned by the said wholly owned subsidiary as that earned by the Appellant A.O stated since the assessee is the only shareholder and holding 100% ......


Mersen India Private Limited,

Payments made for managerial services in terms of paragraph 4 of Article 13 of the DTAC between India and France - Applicant is a 100% subsidiary of a French company service agreement on an automatic renewal of its terms for one year at a stretch ......

2012 (4) TMI 280 - ITAT DELHI

CGG Veritas Services, SA Versus Additional Director of Income-tax, (International Taxation)

Exploration, extraction and production of mineral oil - AO has brought to tax income of the assessee u/s 9(1)(vii) instead of u/s 44BB(1) - Held that:- the assessee suffers no risks even if project of prospecting for or exploration for mineral oil d ......

2012 (4) TMI 271 - ITAT DELHI

Guy Carpenter & Co. Ltd. Versus Assistant Director of Income-tax, International Taxation, Circle 1(2), New Delhi

Receipts in the nature of reinsurance brokerage/commission of the appellant treated by AO as fees for technical services as per Article 13 of the UK DTAA - Tribunals order in assessees own case for AY 2006-07 in his favour - DR relied on a recent r ......

2012 (4) TMI 209 - ITAT CHENNAI

Organisation Development Pte. Ltd. Versus Deputy Director of Income-tax (International Taxation)

Lump sum payment received on sale of software - assessee was giving services to various clients all over the world for development of Balance Score Card (BSC) project - A.O. treated it as royalty under Article 12 of Double Taxation Agreement (DTA) be ......

2012 (4) TMI 190 - ITAT MUMBAI

Uniflex Cables Ltd. Versus Deputy Commissioner of Income-tax, Central Circle 9, Mumbai

Nature of Usance Interest assessee engaged in business of manufacturing of cables of different types imports raw material from parties who are non-residents finance charges/usance charges paid for availing credit under LC - whether usance int ......

2012 (4) TMI 186 - ITAT HYDERABAD

Deputy Director of Income-tax (International Taxation) - I, Hyderabad Versus Dharti Dredging & Infrastructure Ltd.

Payments made by the assessee-company for subcontracting its works contract - payment of hire charges/charter fees to EMPL - royalty u/s 9(1) and article 12 of the DTAA between India and Singapore - Held that:- the contract given to EMPL was in the n ......


Z Versus Director of Income-tax

DTAC between India & Mauritius Taxability of gains arising from transfer of shares and CCDs held by Mauritius company in Indian company Z ltd (Mauritius company) along with Vltd (Indian Company) invested in shares and CCDs of S Ltd (Indian compan ......


Commissioner of Income-tax, International Taxation Versus Rational Software Corpn. India Ltd.

Royalty paid to foreign software Supplier Held that:- Consideration paid by the Indian customers or end-users to the assessee - a foreign supplier, for transfer of the right to use the software/computer programme in respect of the copyrights fells ......

2012 (4) TMI 80 - ITAT MUMBAI

Sumitomo Mitsui Banking Corporation Versus Deputy Director of Income-tax, (IT), Rg. 2(1), Mumbai

Indo-Japan Treaty Japanese Banking company having branch offices in India loan advanced by HO to PE on which interest has been provided by the PE - deductibility of interest payable to the H.O. and other Overseas Branches in the hands of branch o ......



DTAA - No PEs - Fees for technical services - Whether, on the facts and circumstances of the case, the payments received/receivable in connection with following costs incurred/proposed to be incurred for and on behalf of X India, are chargeable to ta ......



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