9911796707
| TMI General Search |
|
Advanced Search Options
Showing 21 to 40 of 1750 Records Search Text: Ip support services india pvt ltd |
| Search Results |
| Articles (6) Case-Laws (1674) Circulars (30) News (28) Notifications (11) Schedules (1) |
|
2018 (6) TMI 618 - AUTHORITY FOR ADVANCE RULINGS, NEW DELHI Fixed place PE of the Applicant in India - Taxability of fees in respect of the services rendered for use of a global network and infrastructure to process card payment transactions for customers in India - DTAA with Singapore - functions performed by MIPs as significant functions - payment card programs are programs of Licensee (i.e. of Banks and FIs) or MasterCard - consideration for use of intangibles in India - Withholding of tax - Held that:- Applicant is carrying out its business of facili... ... ...
2016 (8) TMI 324 - ITAT DELHI Transfer pricing adjustment - royalty payment - Held that:- It it is not necessary for the assessee to show that any legitimate expenditure incurred by him was also incurred out of necessity. It is also not necessary for the assessee to show that any expenditure incurred by him for the purpose of business carried on by him has actually resulted in profit or income either in the same year or in any of the subsequent years. The only condition is that the expenditure should have been incurred “whol... ... ...
2019 (4) TMI 2135 - SECURITIES AND EXCHANGE BOARD OF INDIA Offence under SEBI Act - irregularities in respect of Co-location facility provided by National Stock Exchange of India Ltd. - unfair trade practices - Preferential Treatment of Stock Brokers by NSE - PFUTP Regulations, 2003 application - As alleged Way2Wealth Brokers Private Limited was permitted to avail of Point to Point ( P2P ) dark fiber connectivity from Sampark , a non-empanelled service provider and the P2P connectivity provided by Sampark conferred a latency advantage to W2W which resul... ... ...
2018 (2) TMI 1783 - ITAT DELHI Depreciation on computer peripherals, assessee claimed depreciation on the equipment like UPS, stabilizer, LAN/WAN, catalyst switches, network switches etc. at 60% - Held that:- We find that the equipment forms integral part of the computer systems and the assessee is entitled to the claim of depreciation at 60% by treating the peripherals as part of block of computers. Disallowance of TDS receivables written off - Held that:- In view of the above factual and legal position, it has become necess... ... ...
2023 (12) TMI 205 - ITAT BANGALORE TP Adjustment - comparable selection - HELD THAT:- Following the order of M/s. Sonus Networks India Pvt. Ltd. [ 2020 (10) TMI 663 - ITAT BANGALORE] we direct exclusion of (i) M/s Bodhtree Consulting Ltd, (ii) Tata Elxsi Ltd., (iii) Persistent Systems Ltd. and (iv) Infosys Ltd. from the list of comparables. Sasken Communication Technologies Ltd.and L T Infotech Ltd. are to be excluded from the comparables because this company fails the turnover filter. Disallowance of provision for warranty - App... ... ...
2017 (5) TMI 530 - ITAT HYDERABAD TPA - selection of comparables - Held that:- We find that the assessee is into contracts software development services, backup office support services, marketing support services, corporate IT etc. thus companies functionally dissimilar with that of assessee need to be deselected from final list of comparable.... ... ...
2017 (1) TMI 767 - ITAT HYDERABAD TDS u/s 195 - non deduction of TDS for purchase of copyrighted software - Held that:- The software allegedly purchased by the assessee are the end user software license packages and the remittances are to companies in various countries, such as USA, UK, Germany, Japan, Singapore etc. The copies of the invoices are produced in the form of a paper book and a glance through them shows that the payments are for purchase of End User License packages. The assessee gets the right to use the product. Th... ... ...
2017 (12) TMI 1117 - ITAT KOLKATA TPA - comparable selection criteria - Held that:- Assessee is engaged in cutting edge product without appreciating that the products are not conceptualized in India and hence the role of PSC is limited to only that of a routine captive service provider, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Depreciation claimed by the assessee @ 30% on moulds on the ground that these are used in plastic factories - Held that:- AR has just verbally sub... ... ...
2024 (9) TMI 1254 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL , PRINCIPAL BENCH , NEW DELHI Approval of Resolution Plan - HELD THAT:- The jurisdiction of Adjudicating Authority and the Appellate Tribunal to interfere with the Resolution Plan approved by the CoC, in exercise of its commercial wisdom, are well settled. The limited jurisdiction as has been recognized by the precedents of the Hon ble Supreme Court is when the Resolution Plan is in not conformity with statutory requirements of Section 30, sub-section (2) of the IBC. Thus, the jurisdiction with NCLT and Appellate Tribunal is... ... ...
2020 (11) TMI 1079 - ITAT BANGALORE TP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee engaged in Software Development Services and provides maintenance of service to ARM Limited, UK and ARM Inc, US need to be deselected from final list. Working Capital Adjustment - Direct the TPO to grant Working Capital Adjustment after verification and examination of the assessee computation and allow the ground of appeal of the assessee for statistical purposes.... ... ...
2018 (10) TMI 583 - ITAT KOLKATA TPA - ALP adjustment - methods prescribed under the Act for determination of the ALP of these inter-group services - determination of ALP of the international transaction of payments made under CCA, at NIL by the TPO - Held that:- The factual findings of the Ld. DRP that I.T. services were utilized by the assessee for its own business purpose and any independent enterprise would have to ask and pay for such services is not disputed. We agree with the view of the Ld.CIT(A) that there services are... ... ...
2023 (1) TMI 1066 - ITAT BANGALORE TP Adjustment - comparable Selection - assessee has challenged that the upper turnover of the companies selected by the TPO which are more than 200.00/- crores cannot be considered as a good comparable - HELD THAT:- Respectfully following the decision of the coordinate bench of the Tribunal in the case of Barracuda Networks India Private Limited [ 2022 (5) TMI 322 - ITAT BANGALORE ] we hold that the companies whose turnover in the current year is more than Rs. 200 crores needs to be excluded for... ... ...
2021 (3) TMI 1393 - ITAT BANGALORE TP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee captive software development service providers need to be deselected as comparable. Turnover more than 200 crores and hence cannot be considered as good comparable companies. Disallowance u/s 40(a)(ia) - AR submitted that assessee had deducted tax under relevant provisions of the act. It has been also deposited with the government Treasury but same has not been verified - HELD THAT:- We rem... ... ...
2016 (8) TMI 727 - ITAT HYDERABAD Transfer pricing - Valuation of an intangible asset - revenues generated out of the Intellectual Property (“IP”) or not. - Held that:- What is important is the value available at the time of making business decision. It should be left to the wisdom of the businessman, he knows what is good for the organization. No doubt, ‘IP” was sold to “AE”. The method adopted should be consistent and should be documented to review in the future. The review does not mean replacing the projection with actuals. ... ... ...
2024 (5) TMI 1247 - APPELLATE AUTHORITY FOR ADVANCE RULING, HARYANA The SC ruled on GST classification for franchise licensing services. The Appellate Authority determined the services fall under Service Code 998396 for trademarks and franchises, attracting 18% GST. The appeal was dismissed due to incomplete fee payment, with the appellant failing to meet the statutory requirement of depositing the full prescribed appeal fee under Section 100(3) of CGST Act, 2017.
2023 (3) TMI 399 - ITAT BANGALORE TP adjustment in respect of management fee - these payments were made after deducting taxes prescribed under the relevant DTAA - TPO conclusion on Alleged failure of the assessee to prove the actual receipt of the said service - HELD THAT:- Section 92A(2)(g) get attracted only when one AE provides service to the other AE by allowing the AE to use the know-how, patents, trademark, franchise, etc. and the business of the assessee is wholly dependent on such IP/franchise. Once the foundational cond... ... ...
2022 (9) TMI 1560 - ITAT AHMEDABAD TP Adjustment - Addition on account of Corporate Guarantee Charges - HELD THAT:- In our view, since the issue is directly covered in favour of the assessee in its own case for assessment year 2012-13 and 2013-14 [ 2021 (12) TMI 200 - ITAT AHMEDABAD] wherein held no sound basis for disturbing the arm s length computation of these corporate guarantees, issued by the assessee in favour of its AEs abroad, taken at 1% which has been approved for earlier assessment years as well - we hereby allowing t... ... ...
2017 (10) TMI 1090 - ITAT BANGALORE Google Adword program functions and work - Royalty payment - Use of Intellectual Property through ITES agreement - amount payable by the Appellant to Google Ireland for the subject assessment years - whether the 'distribution rights' are 'Intellectual Property rights' covered by 'similar property' and the distribution fee payable is in relation to transfer of distribution rights? - Held that:- Google is having a targeted geography wise, region wise, gener wise, class wise data base tools. With t... ... ...
2016 (12) TMI 1655 - ITAT DELHI TPA - comparable selection criteria - Held that:- Assessee being global leader in manufacture, integration and support of IP based, end-to-end networking and telecommunication solutions, set up its branch office in India in December 2001, to enable UTS US to offer its products and services in the Indian market. The assessee provides software development services and marketing support and IT Enables customer support services to UTS US Customers in Asia-Pacific region, thus companies functionally ... ... ...
2007 (7) TMI 684 - DELHI HIGH COURT The court granted an anti-suit injunction, restraining Defendant No. 1 from proceeding with the suit in Arizona. It allowed the defendants to use the domain name "indiatvlive.com" with a disclaimer and directed Defendant No. 1 to file revenue statements from the website in India every six months. The court found prima facie evidence of a connection between the defendants and held that the plaintiff's mark "INDIA TV" was protectable. The court dismissed claims of undue delay in filing the suit and concluded that the observations made would not impact the final disposal of the case.
|
