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Showing 41 to 60 of 1750 Records Search Text: Ip support services india pvt ltd |
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2023 (7) TMI 1241 - DELHI HIGH COURT Money Laundering - Whether an Online Payment Gateway Service (OPGSP) could be said to be a Reporting Agency under the PMLA? - It is the case of the respondents that PayPal is a payment system operator and thus a reporting entity. Money Laundering - Global Experiences - HELD THAT:- The FIU-IND essentially acts as the central nodal agency for receiving, processing and analysing information relating to suspicious financial transactions. It is thus tasked with the collection of information, analysis... ... ...
2016 (5) TMI 1624 - COMPETITION APPELLATE TRIBUNAL, NEW DELHI Suppression of facts by the Informant makes the present proceedings infructuous - penalty under section 45(1)(b) of the Competition Act, 2002 - contravention of any of the provisions of section 3 of the Act. Whether the suppression of facts by the Informant makes the present proceedings infructuous, as alleged by the Opposite Parties? - Whether the Informant is liable to be penalized under section 45(1)(b) of the Act? - HELD THAT:- Although it is not intended to penalise Respondent No. 2 by impo... ... ...
2013 (9) TMI 374 - ITAT MUMBAI TDS deduction u/s 195 - Purchase of software - Scope of term Copy Right - DTAA with Australia - Whether purchases of software or payment of Royalty be liable for deduction of TDS - Held that:- It is no doubt true the provisions of the DTAA overrides the provisions of the Income-tax Act. In the DTAA the term royalty means payments of any kind received as a consideration for the use or the right to use any copyright of literary, artistic or scientific work whereas in the Income-tax Act, royalty me... ... ...
2025 (5) TMI 193 - ITAT MUMBAI ITAT resolved multiple tax appeal issues in favor of the assessee. The tribunal quashed the assessment order for non-compliance with Dispute Resolution Panel (DRP) directions, deleted disallowances of franchisee fees and intra-group service charges, and allowed deductions under section 80G. The key findings emphasized procedural compliance, arm's length pricing principles, and statutory interpretation of transfer pricing regulations. Revenue's contentions were largely rejected based on lack of evidence and improper application of tax laws.
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 ... ... ...
2022 (2) TMI 514 - ITAT BANGALORE Income accrued in India - Receipts on sale of hardware with embedded software - royalty receipts - DTAA between India and UK - assessee is a non-resident foreign company incorporated in United Kingdom - AR submitted that assessee granted exclusive non-transferrable license to customers in India to enable them to use the software for provision of DTH services to Indian subscribers - HELD THAT:- As decided in own case [ 2021 (11) TMI 1023 - ITAT BANGALORE] that pure reimbursement does not give ris... ... ...
2021 (11) TMI 1023 - ITAT BANGALORE Income accrued in India - Hardware receipts held to be chargeable to tax in India - receipts on sale of hardware with software embedded therein can be taxed as royalty or not? - assessee is a non-resident foreign company incorporated in United Kingdom - hardware is primarily in the form of viewing cards, Set-top-Box (STB) and other connected components,usually used in viewing television through satellite. The embedded software is required to run the hardware components - assessee claimed before ... ... ...
2021 (9) TMI 1485 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL, NEW DELHI Winding up of Company - fraudulent conduct - failure to disclose that the limitation to file a winding up petition is three years from when the right to apply accrues as per Article 137 of the Limitation Act, 1963 - exclusive jurisdiction of Tribunal to adjudicate matters under Section 271(c) of the Companies Act, 2013 - contention of Appellant is that a private dispute of the Agreement dated 28.01.2005 executed between the Appellant and the 1st Respondent cannot be a part of fraud as per Sectio... ... ...
2021 (2) TMI 575 - ITAT DELHI TP Adjustment - Comparable selection - functional dissimilarity - HELD THAT:- Assessee is into rendering Information Technology Enabled Services (ITES) related to IP administration/renewal and data management services to its group companies including renewal support services, proof reading support, customer support services etc.. The taxpayer functions as a captive off-shore centre in India and supports its Associated Enterprises (AEs) in servicing customer contracts, thus companies functinally ... ... ...
2020 (5) TMI 731 - ITAT DELHI TP Adjustment - comparable selection - RPT filter @ 25% - HELD THAT:- We are of the considered opinion that this matter requires verification at the level of TPO for determination of the inclusion and/or exclusion of this comparable on the basis of RPT filter as adopted by the assessee and the TPO. We, therefore, deem it proper to restore this issue to the file of the AO/TPO for deciding this issue afresh after verification of the RPT from the financials already furnished by the assessee. Ground... ... ...
2019 (12) TMI 1279 - ITAT BANGALORE TP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee is engaged in the business of software development and related services to its Associated Enterprises (AEs), SSIPL, wholly subsidiary of EMC Corporation, USA and the assessee was registered under SEZ on 14th August, 2008 for rendering IT and ITES to EMC Group of Companies and is compensated on mark up on cost basis for services provided and know how, copy rights etc. and other commercial and marketing services... ... ...
2018 (4) TMI 878 - ITAT DELHI Transfer pricing addition - comparable selection criteria - functional similarity - Held that:- The assessee is engaged in the business of development of computer software for its Associated Enterprises (AEs), thus companies functionally dissimilar with that of assessee need to be deselected from final list.... ... ...
2018 (4) TMI 429 - ITAT BANGALORE TPA - comparable selection criteria - Held that:- Assessee is classified into software development segments, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Risk adjustment qua comparables and the assessee - Held that:- It is for the assessee to demonstrate as to how the assessee who is a captive service provider to its AE has more risk in comparison to the other comparables retained by the Tribunal. Since no details and working has been provid... ... ...
2017 (1) TMI 1215 - ITAT DELHI Transfer pricing adjustment - ALP determination - grant of working capital adjustment - Held that:- Respectfully following the finding in the case of Mercer Consulting (India) Private Limited (2014 (7) TMI 715 - ITAT DELHI), we set aside the finding of the DRP on the issue in dispute and remit the matter to the file of the TPO/AO for examining the assessee’s claim for grant of working capital adjustment on merits and, thereafter, allow the same, if it is available. The assessee shall be afforded... ... ...
2016 (8) TMI 1195 - ITAT DELHI TPA - selection of comparable - Held that:- Assessee is engaged in the business of distribution and sale of Digital Switching Equipment, Cellular Exchange Equipment and Other Telecommunication Equipment and also provides related services. The assessee also provides Contract Software Development (CSD) Services and Technical Support Services (TSS), thus companies dissimilar with that of assessee need to deselected from final list of comparable. Working capital adjustment and risk adjustment - Held... ... ...
2016 (7) TMI 1318 - ITAT DELHI TPA - selection of comparable - Held that:- The assessee has been operating in India through a Branch office and is in the business of development of computer software. The software developed by the branch office in India is integrated with software developed by the parent entity, thus companies functinally dissimilar with that of assessee need to excluded from final list of comparability. Risk adjustment - Held that:- It would be appropriate in the peculiar facts and circumstances restore the i... ... ...
2015 (5) TMI 726 - ITAT DELHI Revenue earned from supply of software taxed as “Royalty” - DTAA between India and USA - Held that:- Respectfully following the decision of Ericsson A.B. (2011 (12) TMI 91 - Delhi High Court) and Infrasoft Ltd. (supra), we hold that the consideration received by the Assessee for supply of product along with license of software to End user is not royalty under Article 12 of the Tax Treaty. Even where the software is separately licensed without supply of hardware to the end users (i.e. eight out o... ... ...
2015 (5) TMI 932 - ITAT DELHI TP Adjustments - Disregarding Profit Split Method ('PSM') as the most appropriate method for benchmarking Appellant's international transactions - held that:- The claim of the assessee that the issue is covered by the order of the Co-ordinate Bench in GOIPL [2014 (4) TMI 787 - ITAT DELHI] wherein held that when a transaction is integrated and interrelated and when costs are incurred by multiple entities and the revenues are to be apportioned to multiple entities, then the factual conclusions of ... ... ...
2008 (5) TMI 736 - COMPANY LAW BOARD, CHENNAI The Company Law Board (CLB) dismissed the petitioner's claims of oppression and mismanagement, upheld the validity of meetings and resolutions, and directed the petitioner to exit the company by selling its shares to the second respondent. The CLB found that the second respondent's efforts to revive the company justified the petitioner's exit, emphasizing the company's survival as the paramount interest.
2025 (4) TMI 1131 - ITAT DELHI Tribunal ruled that service fees from an Indian affiliate to a US company were not taxable as Fees for Technical Services (FTS) under the India-USA DTAA. Despite services being technical in nature, they did not satisfy the critical "make available" clause, which requires transfer of technical knowledge enabling independent use. The appeal was allowed, deleting INR 77,311,738 from taxable income and directing full TDS credit verification.
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