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 ......
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 ......
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