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Income Tax Case Laws - Section: 9

 

Income Tax

Cases for Section: 9

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Showing 361 to 375 of 929 Records
 

2012 (6) TMI 328 - ITAT DELHI

Pizza Hut International LLC C/o Dinesh Mehta & Co. Versus Deputy Director of Income-tax, Circle 2(1), International Taxation

DTAA between India and USA - Royalty income - taxability on gross basis or net basis - assessee opted for the provision contained under article 12 of DTAA contemplating taxation @ 15% of the "gross amounts" of royalties - Held that:- Term "Gross amou ......

2012 (6) TMI 314 - ITAT BANGALORE

Income-tax Officer, International Taxation, Ward-19(1), Bangalore Versus Bovis Lend Lease (India) (P.) Ltd.

Recall/rectification of order - typographical error - TDS assessee in default - held that:- In the light of the conclusion in the preceding sentence, the usage of the word 'NOT' in the above sentence appears to be a typographical error. Accordingly ......

2012 (6) TMI 294 - ITAT DELHI

Metal One Corporation Versus Deputy Director of Income-tax, Circle - 3(1), International Taxation

DTAA between India and Japan - Whether Liasion Office maintained in India under approval of RBI constitutes its Permanent Establishment in terms of Article 5 of said DTAA - assessee submitted that office was carrying on preparatory or auxiliary work ......

2012 (6) TMI 290 - ITAT MUMBAI

Deputy Director of Income-tax (International Taxation) 2(1), Mumbai Versus Toyo Engineering Corpn.

Percentage of completion method of accounting Held that:- The assessee revised its basis of accounting from the invoicing schedule method to the percentage of completion method for computing revenues arising from the project management and onshore ......

2012 (6) TMI 232 - KARNATAKA HIGH COURT

Commissioner of Income-tax, International taxation Versus Rational Software Corpn. (India) Ltd.

Whether the 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 falls within the mischief of 'royalty' as defined ......

2012 (6) TMI 203 - KARNATAKA HIGH COURT

Commissioner of Income-tax, International Taxation Versus Sonata Information Technology Ltd.

Whether the 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 falls within the mischief of 'royalty' as defined ......

2012 (6) TMI 187 - AUTHORITY FOR ADVANCE RULINGS

Aramex International Logistics Versus Director of Income-tax

DTAC between India and Singapore - permanent establishment - applicant (Singapore Company) being part of Aramex group of companies who is in the business of international express, entered into an agreement dated 1.4.2010 with AIPL(Indian subsidiary o ......

2012 (6) TMI 186 - AUTHORITY FOR ADVANCE RULINGS

Alstom Transport SA Versus Director of Income-tax

DTAA between India and France - Consortium Contract - taxability of amount receivable under project by appellant (foreign company) - contract awarded by Bangalore Metro Rail Corporation Limited to implement the design, manufacture, supply, installati ......

2012 (6) TMI 111 - ITAT DELHI

CGG Marine Resources Versus Deputy Commissioner of Income-tax, International Taxation-II, New Delhi

Application of section 44D or section 44BB - revision u/s 263 - providing equipment and services in connection with prospecting and extraction or production of mineral oil. - Leasing of seismic vessel to to the CGG - CGG used the vessel for collectin ......

2012 (6) TMI 106 - MADRAS HIGH COURT

M/s. Aktiengesellaschaft, Kunhle Kopp & Kausch, Germany Versus The Deputy Commissioner of Income Tax

Rate of tax u/s 115A - royalty - Amended collaboration agreement entered in 1981 to be treated as an extension of the old agreement of 1973 - the assessee claimed relief of deduction of 20% towards expenses, further deduction of 20% towards training ......

2012 (6) TMI 18 - AUTHORITY FOR ADVANCE RULINGS

Solar Turbines International Company

DTAA between India & USA - contract for repair and overhauling services of turbines - whether Fees for Technical Services(FTS) - assessee (USA company) in addition to contract for supply and installation of turbines had entered into yet another contr ......

2012 (6) TMI 15 - ITAT MUMBAI

DDIT(IT) 3(2) Versus B4U International Holdings Ltd.

Dependent Agent - Permanent Establishment - assessee, a Mauritius company, engaged in telecasting TV channels had an advertisement collection agent in India who collected revenue from time slots given to Indian advertisers - assessee claimed that its ......

2012 (5) TMI 503 - ITAT MUMBAI

B4U International Holdings Ltd. Versus DCIT (IT) 3(2) Mumbai.

Dis-allowance 40(a)(i) on payment of hiring charges for transponder by assessee(Mauritius company), to foreign companies on the ground that no tax has been deducted at source by the assessee u/s 195 - Revenue contending such hiring charges to be Roya ......

2012 (5) TMI 499 - ITAT, Ahmedabad

Prakash Chandra Juglubhai Lonari Versus ITO

TDS u/s 194C - Liability of Individual / HUF - receipt from its cable network subscribers - Disallowance u/s 40(a) (ia) - Circular No.715 dated 8/08/1995 - applicability of provisions of sub-section (2) of section 194C of the Act. - held that:- In th ......

2012 (5) TMI 449 - DELHI HIGH COURT

Commissioner of Income-tax Versus Havells India Ltd.

Pre-operative expenses - revenue or cpaital expenditure - Non deduction of TDS - testing charges paid to the US Company - Disallowance u/s 40(a)(i) - fee for technical services under Section 9(1)(vii)(b) - held that:- the fees for technical services ......

 
   
 
 
 

 

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