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2023 (8) TMI 445 - ITAT MUMBAI Income taxable in India - payment received by the assessee towards TSIS services - Royalty receipts - HELD THAT:- It is noticed that the assessee has entered into an agreement with the Indian companies for rendering TSIS services and the terms of the agreement as per the submission of the ld AR are verbatim similar to the agreement which were in force for A.Ys. 2012-13 to 2015-16. It is also noticed that the DRP while upholding the treatment of TSIS fees as royalty, while following its own order... ... ...
2023 (4) TMI 1163 - ITAT MUMBAI Income deemed to accrue or arise in India - Royalty or Fees for Technical Services - assessee received consideration for project support services such as Midrange support services, Database support services, Service delivery management, and support services in relation to the Standard Chartered Bank Project from Atos India - AO held the consideration received by the assessee from the Indian entity is nothing but Royalty within the definition as per Article 12(3) of the India Singapore DTAA - HEL... ... ...
2021 (4) TMI 446 - ITAT MUMBAI Income deemed to accrue or arise in India - Taxability of certain amount received from the Indian subsidiary - PE in India - royalty or/and fees for technical services (FTS) - assessee is a company incorporated in Singapore and is also a tax resident of that country - HELD THAT:- On a careful reading of Article 12(4) of the tax treaty, it becomes very much clear that Article 12(4)(a) and 12(4)(c) are not applicable to the present case. Insofar as Article 12(4)(b) is concerned, it clearly denotes... ... ...
2021 (1) TMI 76 - ITAT MUMBAI Income accrued in India - taxability of receipt towards Infrastructure and Hosting Data Centre (IDC) charges by treating it as royalty - India Singapore DTAA - assessee is a company incorporated in Singapore and is engaged in provision of services relating to developing, marketing and implementing incentive based strategies and technologies to build loyalty and to reward long-term relationships through the utilization of the internet, wireless technology and offline solutions to its clients - Du... ... ...
2019 (4) TMI 1245 - ORISSA HIGH COURT Rectification of mistake in GST TRAN-1 of the petitioner s declaration - transitional credit - post GST Regime - main contention of the petitioner is that the petitioner while putting his Form has committed an error - whether the petitioner has a prima facie case for consideration? HELD THAT:- High Court of Madras, in the case of MSR Iron and Steel Industries India Private Limited and others v. Joint Commissioner of Sale Taxes, Coimbatore Division, Coimbatore and others [ 2018 (9) TMI 543 - MADR... ... ...
2016 (11) TMI 290 - ITAT DELHI Deduction u/s 10A - call centre - AO submitted that the activities of the assessee were not in the nature of call centre and, therefore, the assessee was not entitled for deduction under section 10A - Held that:- From the facts elaborated by the assessee there is no dispute that it is a call Centre engaged in managing accounts receivable and recovery. The calls are made by the “Predictive Dialer Software” and after the call the inputs of the relevant information obtained from the data of the US ... ... ...
Goods and GST Bill passed The discussion on the Goods and Services Tax (GST) Bill highlights its passage in the Rajya Sabha on August 3, 2016, and the subsequent debates and updates regarding its implementation. The GST aims to create a unified tax system by subsuming various indirect taxes. Key issues include the determination of tax rates, with a proposed revenue-neutral rate of 15-15.5% and a standard rate of 17-18%. The GST Council, led by the central finance minister and state finance ministers, is tasked with finalizing these rates. The discourse also covers the challenges of increased compliance, the need for IT infrastructure, and the impact on different sectors. The rollout target was initially set for April 1, 2017, but was later adjusted to July 1, 2017, to allow for smoother transition and preparation.
The Department of Disinvestment and Expenditure under India's Ministry of Finance reported significant achievements in fiscal year 2015-16, including a record disinvestment receipt of Rs. 24,349 crore in 2014-15 and raising Rs. 12,700 crore in the first half of 2015-16. The department adopted a rolling plan approach to enhance flexibility and efficiency in disinvestment processes. Additionally, the Finance Commission increased states' share in Union taxes to 42%, enhancing fiscal autonomy. The Seventh Pay Commission recommended pay increases, impacting the fiscal budget. Efforts to streamline pension processes and improve financial management systems were also highlighted, contributing to improved governance and efficiency.
2012 (2) TMI 534 - ITAT MUMBAI TDS u/s 195 - Held that:- When the equipments were not operated, used or under the control of the assessee, then the payments made for availing the services of Rackspace cannot be said as royalty. When the payments are not in the nature of royalty as per Indo-USA DTAA as well as per Explanation 2 (via) of Sec. 9(1) of the I T Act, then recipient of the said payments being non-resident having no PE is not liable to tax in India. Therefore, the payments in the hands of Rackspace are not taxable in... ... ...
2019 (5) TMI 622 - ITAT DELHI TPA - comparable selection - functional dissimilarity - captive Data processing services - HELD THAT:- Eclerx services Ltd is not a comparable company with the ITeS segment of the assessee. Therefore, we direct the learned transfer pricing officer/AO to exclude this company. Infosys BPO Ltd - Exclude the same from the comparability analysis for the reasons of having huge brand value. TCS E serve international Ltd is a subsidiary of Tata consultancy services Ltd. - it belongs to a Tata group and ... ... ...
2012 (2) TMI 599 - ITAT DELHI The Tribunal found that the rejection of the application for renewal of exemption under section 80G of the Income Tax Act was illegal and unsustainable. It concluded that the Trust's activities were charitable, focusing on education and skill development, and that payments made were for legitimate services. The Tribunal directed the DIT(E) to grant approval under section 80G to the Trust, as the rejection was deemed arbitrary. The appeal was partly allowed, and the order was pronounced on 10.02.2012.
2025 (4) TMI 825 - CESTAT BANGALORE The SC/Tribunal determined that Annual Technical Support (ATS) services are fully subject to service tax, rejecting claims of partial VAT applicability. The court found no evidence of goods sale, disallowed abatement claims, and limited tax demand to the standard limitation period. The appellant was required to pay service tax on 100% of the invoice value for ATS services.
2023 (11) TMI 390 - ITAT DELHI TDS u/s 195 - disallowances u/s 40(i)(a) - payments made to Dubai Leading Technologies - whether India-UAE DTAA has no clause on Fee for Technical Services? - HELD THAT:- We do not find any infirmity in the order of the Ld. CIT(A) and uphold his finding that the payments made to Dubai Leading Technologies cannot be brought to tax under Article 22 in the absence of a specific clause for FTS in the India-UAE DTAA. The impugned payments are in the nature of business income which are not chargeable ... ... ...
2023 (3) TMI 778 - ITAT MUMBAI TP adjustment - payment of cost allocation charges towards Central Regional Support Services and Business Support Services - HELD THAT:- Once availing of various services from the associated enterprise is duly substantiated by the documentary evidence and the cost allocation among the group companies is also on the basis of a well-accepted allocation key method, we find no basis in upholding the transfer pricing adjustment made by the TPO/AO. Accordingly, the AO is directed to delete the transfe... ... ...
2023 (1) TMI 1207 - ITAT MUMBAI Income deemed to accrue or arise in India - TSIS Service Fee received by the assessee is taxable as royalty- India France DTAA - HELD THAT:- We find that the taxability of income arising from similar services rendered by the assessee s group concern, namely, Edenred PTE Ltd came up for consideration before the coordinate bench of the Tribunal in Edenred PTE Ltd [ 2021 (1) TMI 76 - ITAT MUMBAI] for the assessment year 2013-14. The coordinate bench of the Tribunal after considering the facts of th... ... ...
2022 (4) TMI 1390 - GUJARAT HIGH COURT Validity of assessment u/s 144B - As argued no draft assessment order was served upon the writ applicant in accordance with the provisions of Section 144B prior to passing of the impugned assessment order - whether the respondent committed any error in passing the impugned order? - HELD THAT:- What is important to be noted in the present case is that it is not just a question of giving an opportunity of hearing and for that purpose, the assessee should have the draft assessment order in his hand... ... ...
2021 (12) TMI 313 - GUJARAT HIGH COURT Validity of order u/s 144B - Faceless assessment - violation of principles of natural justice - Argument of Non service of any Draft Assessment Order as well as show cause notice - HELD THAT:- As the chronology of the events presented before us by the respondent authority that the return of the petitioner Company was selected for scrutiny and notice u/s 143(2) of the Act was issued on 22.09.2019. Date of hearing was fixed on 07.10.2019. Various responses have been given by the petitioner. It als... ... ...
2021 (8) TMI 927 - ITAT BANGALORE Royalty u/s 9(1)(vi) - TDS u/s 195 - Validity of demand raised u/s 201(1) and interest charged u/s 201(1A) - Assessee sells its products mainly through online marketing. - AO has mainly invoked the provisions of sec. 9(1)(vi) of the Act in respect of payments made to M/s Facebook and M/s Rocket Science Group (MailChimp) to hold that the same is royalty - for payments made for Amazon Web Services, the AO has also referred to the provisions of DTAA entered into India and USA in addition to sec.9(1... ... ...
2020 (7) TMI 644 - ITAT MUMBAI Income accrued in India - Royalty receipt - revenues under the IDC agreement - India-Singapore DTAA - HELD THAT:- We find that in the instant case, appellant only provides service by using its hardware/security devices/personnel and not use of any software - the appellant is only providing IDC service which includes administration and supervision of central infrastructure, mailbox hosting services and website hosting services. From the enunciation of law in Bharati Axa General Insurance Co. Ltd ... ... ...
2016 (11) TMI 1249 - ITAT MUMBAI Taxability of “Management Service Fees” - whether amount received by the assessee from its Indian entity as “royalty” under Article 12(4) of Indian- Netherlands Treaty - Held that:- As highlighted above, with regard to various streams of services like providing of information technology; operational support; marketing; quality, health, safety and environment; estimating and engineering; and personal and organization, administration and legal services, there is no imparting of any kind of knowled... ... ...
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