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 ......
2012 (2) TMI 365 - ITAT MUMBAI
UPS SCS (Asia) Ltd. Versus Assistant Director of Income-tax (International Taxation) -2(2), Mumbai
Fees for technical services – Revenue treated transportation fees receivable as FTS u/s 9(1)(vii) – Hongkong company – engaged in the business of provision of supply chain management, including the provision of freight and forwarding and logistics se ......
2012 (2) TMI 364 - Authority for Advance Rulings
SKF Boilers & Driers (P.) Ltd., In re
Income deemed to accrue or arise in India - export commission payable to non-resident agents – withholding of tax - Held that:- No doubt the agents rendered services abroad and have solicited orders, but the right to receive the commission arises in ......
2012 (2) TMI 260 - AUTHORITY FOR ADVANCE RULINGS
Global Industries Asia Pacific Pte. Ltd., In re
DTAA with Singapore – Singapore company entered into contract with IOCL for residual offshore construction work and Installation of SPM - contract with L&T Ltd for installation and construction services for Single Point Mooring (SPM) - applicant cont ......
2012 (2) TMI 258 - AUTHORITY FOR ADVANCE RULINGS
Citrix Systems Asia Pacific Pty. Limited,
DTAA with Australia – Australian company entered into distribution agreement with Indian Company(IMI Ltd) for the distribution and sale of its software and hardware products in India - sale and collection of software product is made through the distr ......
2012 (2) TMI 173 - AUTHORITY FOR ADVANCE RULINGS
AREVA T&D India Ltd., In re
Indo-French DTAA – French Company entered into an IT Agreement with the applicant to provide support services in the area of IT - whether royalty or FTS – whether payment would fall under the provisions of Article 13 of the Indo France DTAA in view o ......
2012 (2) TMI 98 - AUTHORITY FOR ADVANCE RULINGS
Shell India Markets (P.) Ltd., In re
Double Taxation Avoidance Convention between India and UK – Cost Contribution Agreement ("CCA") with SIPCL (company incorporated in UK) for availing General Business Support Services (General BSS) - determination of nature of payments made to SIPCL a ......
2012 (2) TMI 75 - AUTHORITY FOR ADVANCE RULINGS
CTCI Overseas Corpn. Ltd., In re
Off-shore supplies & services - applicant being Hong Kong company – project awarded by Petronet - consortium formed with an Indian company(CINDA), to execute the project - CTCI responsible for off-shore supplies & services & CINDA for onshore supplie ......
2012 (2) TMI 74 - AUTHORITY FOR ADVANCE RULINGS
SEPCO III Electric Power Construction Corporation, In re
Off- shore supply contract – India-China Double Taxation Avoidance Convention - applicant being company of China – contract for supply of equipment to Indian company - Indian company, defined as the owner in the contract - passing of the title to t ......
2012 (1) TMI 52 - SUPREME COURT OF INDIA
Vodafone International Holdings BV. Versus Union of India & Anr.
Scope of total income - Revenue seeks to tax the capital gains arising from the sale of the share capital of CGP on the basis that CGP, whilst not a tax resident in India, holds the underlying Indian assets. - Held that:- Applying the look at test in ......
2012 (1) TMI 5 - DELHI HIGH COURT
DIRECTOR OF INCOME TAX Versus RIO TINTO TECHNICAL SERVICES
DTAA with AUSTRALIA – Fees for technical services (FTS) or inclusive contracts of technical nature - applicability of Articles 7 or 12 of the DTAA – assessee having PE in India – whether income to be construed as business income or gross receipts ......
2011 (12) TMI 195 - ITAT MUMBAI
ADIT (International Taxation) -2(2) Versus Warner Brother Pictures Inc.
Royalty for exclusive rights of distribution of Cinematographic films – India-USA Treaty assessee is a non-resident company having no PE in India – agreement with Warner Bros Pictures (India) Pvt. Ltd(WBPIPL) for grant of rights – WBPIPL deducted tax ......
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