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 ......
2012 (4) TMI 154 - AUTHORITY FOR ADVANCE RULINGS
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 ......
2012 (4) TMI 116 - KARNATAKA HIGH COURT
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 ......
2012 (4) TMI 74 - AUTHORITY FOR ADVANCE RULINGS
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 ......
2012 (3) TMI 281 - AUTHORITY FOR ADVANCE RULINGS
Linde AG. Linde Engineering Division
Turnkey project taxability of amount receivable under project - DTAA between India and Germany - consortium formed by applicant (German company) and Samsung (Korean company) to undertake the project of carrying work of all activities and services r ......
2012 (3) TMI 259 - ITAT DELHI
Deputy Director of Income-tax, International Taxation, Circle 2(2) Versus Sheraton International Inc.
Article 12 of DTAA - The assessee had entered into agreements with the ITC Hotels Ltd to provide marketing and advertising services through sales, promotion, public relations and reservations - income received in the form of marking fees for services ......
2012 (3) TMI 242 - AUTHORITY FOR ADVANCE RULINGS
FTS - IVTC services - Whether payment received by the applicant in connection with transactions undertaken in relation to the Inspection, Verification, Testing and Certification (IVTC) services are chargeable to tax in India as FTS u/s 9(1)(vii)(b) ......
2012 (3) TMI 104 - ITAT MUMBAI
ADIT (International Taxation) Versus Jet Airways (India) (P.) Ltd.
DTAA between India and UK - appellant had made a request u/s. 195 for non deduction of tax from the payment made to ARL - The request was rejected by the DCIT, TDS Circle-1(1), vide his order u/s. 195 dt. 1.12.1998 - Ld. Counsel for the appellant on ......
2012 (3) TMI 98 - BOMBAY HIGH COURT
Atlas Copco AB of Sweden Versus Commissioner of Income-tax, Bombay
Capital Gain-Whether lump-sum consideration is a capital receipt in the hands of the assessee company- held that:-the amounts were paid to the assessee on account of right to use the know how for a specified period and no outright transfer of know ho ......
2012 (3) TMI 27 - ITAT DELHI
Deputy. Director of Income-tax Versus M/s. Western Union Financial Services Inc.
Depended agent or independent agent - Money Transfer Business - Stand alone Machines - liaison office versus Permanent Establishment - held that:- Non-banking financial companies deal with money belonging to others and the activity of paying out moni ......
2012 (2) TMI 406 - ITAT MUMBAI
The DDIT (IT) 2(1) Versus M/s. Solid Works Corporation
TDS - Assessee develops and markets 3D Solutions - sale of shrink wrap software - Royalty - NO Permanent Establishment(PE) - Held That:- In view of DIT Vs. Ericsson AB, (2011 - TMI - 207919 - Delhi High Court) consideration received by the Assessee ......
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