2012 (6) TMI 187 - AUTHORITY FOR ADVANCE RULINGS
Aramex International Logistics Versus Director of Income-tax
DTAC between India and Singapore - permanent establishment - applicant (Singapore Company) being part of Aramex group of companies who is in the business of international express, entered into an agreement dated 1.4.2010 with AIPL(Indian subsidiary o ......
2012 (6) TMI 186 - AUTHORITY FOR ADVANCE RULINGS
Alstom Transport SA Versus Director of Income-tax
DTAA between India and France - Consortium Contract - taxability of amount receivable under project by appellant (foreign company) - contract awarded by Bangalore Metro Rail Corporation Limited to implement the design, manufacture, supply, installati ......
2012 (6) TMI 111 - ITAT DELHI
CGG Marine Resources Versus Deputy Commissioner of Income-tax, International Taxation-II, New Delhi
Application of section 44D or section 44BB - revision u/s 263 - providing equipment and services in connection with prospecting and extraction or production of mineral oil. - Leasing of seismic vessel to to the CGG - CGG used the vessel for collectin ......
2012 (6) TMI 106 - MADRAS HIGH COURT
M/s. Aktiengesellaschaft, Kunhle Kopp & Kausch, Germany Versus The Deputy Commissioner of Income Tax
Rate of tax u/s 115A - royalty - Amended collaboration agreement entered in 1981 to be treated as an extension of the old agreement of 1973 - the assessee claimed relief of deduction of 20% towards expenses, further deduction of 20% towards training ......
2012 (6) TMI 18 - AUTHORITY FOR ADVANCE RULINGS
Solar Turbines International Company
DTAA between India & USA - contract for repair and overhauling services of turbines - whether Fees for Technical Services(FTS) - assessee (USA company) in addition to contract for supply and installation of turbines had entered into yet another contr ......
2012 (6) TMI 15 - ITAT MUMBAI
DDIT(IT) 3(2) Versus B4U International Holdings Ltd.
Dependent Agent - Permanent Establishment - assessee, a Mauritius company, engaged in telecasting TV channels had an advertisement collection agent in India who collected revenue from time slots given to Indian advertisers - assessee claimed that its ......
2012 (5) TMI 503 - ITAT MUMBAI
B4U International Holdings Ltd. Versus DCIT (IT) 3(2) Mumbai.
Dis-allowance 40(a)(i) on payment of hiring charges for transponder by assessee(Mauritius company), to foreign companies on the ground that no tax has been deducted at source by the assessee u/s 195 - Revenue contending such hiring charges to be Roya ......
2012 (5) TMI 499 - ITAT, Ahmedabad
Prakash Chandra Juglubhai Lonari Versus ITO
TDS u/s 194C - Liability of Individual / HUF - receipt from its cable network subscribers - Disallowance u/s 40(a) (ia) - Circular No.715 dated 8/08/1995 - applicability of provisions of sub-section (2) of section 194C of the Act. - held that:- In th ......
2012 (5) TMI 449 - DELHI HIGH COURT
Commissioner of Income-tax Versus Havells India Ltd.
Pre-operative expenses - revenue or cpaital expenditure - Non deduction of TDS - testing charges paid to the US Company - Disallowance u/s 40(a)(i) - fee for technical services under Section 9(1)(vii)(b) - held that:- the fees for technical services ......
2012 (5) TMI 345 - AUTHORITY FOR ADVANCE RULINGS
´A´ Systems, In re
Whether payments made to the applicant (a company based in Germany), in terms of the Cost Allocation Agreement, can be treated as income in the hands of the applicant and whether it is not merely a reimbursement of the expenses incurred for the Resea ......
2012 (5) TMI 206 - ITAT AHMEDABAD
Mastek Ltd. Versus Additional Commissioner of Income-tax, Range - 4, Ahmedabad
Transfer pricing - Arms Length price (ALP) - associated enterprises - Software Development Activity - selling agent (or markteing office) versus distributor - held that:- there was no direct evidence in the hands of the TPO to say that the assessee ......
2012 (5) TMI 191 - KARNATAKA HIGH COURT
Commissioner of Income-tax Versus De Beers India Minerals (P.) Ltd.
Fees for technical services - meaning of "make available" - Section 9(l)(vii) of the Income Tax read with Article 12(5) of the DTA agreement between India and Netherlands - services to supply technical data including drawings, plans, maps etc., (geo ......
2012 (5) TMI 185 - ITAT MUMBAI
Bhagwan T. Shivlani Versus Income-tax Officer (IT) -2(2), (Mumbai)
The expression liable to tax - Non residents - DTAA between India and UAE. - Relief under Explanation 1(b) of Sec. 9(1)(i) of the Income Tax Act, 1961 - Export of electronic goods and plastic mould to Dubai and Nigeria. - Deduction u/s 80HHC - h ......
2012 (5) TMI 179 - ITAT PUNE
Allianz SE Versus Assistant Director of Income-tax, (International Taxation)-I, Pune
Transactions under a software license agreement - assessee a German company taxed as a non-resident in India owning 26% of the shareholding in two Insurance companies in India – Revenue treated transaction towards Royalty receipt within the meaning o ......
2012 (5) TMI 175 - ITAT DELHI
Hughes Escort Communications Ltd. Versus Deputy Commissioner of Income-tax, Circle 2(2), New Delhi
DTAA with USA - withholding tax (TDS) - Affiliate Agreement - sharing of fee - Distance learning courses - information through website situated outside India - permanent establishment or business connection - held that:- nature of payment made to ......