2015 (4) TMI 979 - GUJARAT HIGH COURT
M/s E-INFOCHIPS LIMITED Versus DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4
Reopening of assessment - non deduction of tds on payment credit to foreign companies, on account of software services - Held that - In the original assessment, full particulars with respect to Software License Fees by the assessee to the foreign com.....
2015 (4) TMI 191 - MADRAS HIGH COURT
The Commissioner of Income Tax Versus M/s. Fluidtherm Technology Pvt. Ltd.,
Disallowance u/s 40(a)(ia)- Non deduction of TDS on export commission paid by the assessee to the non-resident - ITAT deleted the disallowance - Held that - The facts of the present case are akin to the facts of the decision in Toshoku Ltd.'s cas.....
2015 (3) TMI 939 - DELHI HIGH COURT
Agence Frances Press Versus Asst. Dirctor of Income Tax
Interest under Section 234B - non-payment of advance tax - non deduction of tds - Held that - As relying on DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION Versus GE PACKAGED POWER INC. AND OTHERS 2015 (1) TMI 1168 - DELHI HIGH COURT no interest is lev.....
2015 (3) TMI 719 - MADRAS HIGH COURT
Commissioner of Income Tax Versus M/s. Orient Express
Non deduction of tds - payments made by the assessee to the non-residents - whether the relationship between the appellant and the agents is contractual and entire service is provided outside India and duly compensated by way of commission payment wh.....
2015 (3) TMI 491 - ITAT AHMEDABAD
Gujarat State Petroleum Corporation Limited Versus JCIT
Reopening of assessment - Disallowance of claim u/s 42 - principle of merger - CIT(A) allowed part relief - Held that - In the present case, notice u/s 148 of the Act has been issued on 24.12.2008 in relation to Assessment Year 2001-02 and hence, reo.....
2015 (3) TMI 399 - ITAT BANGALORE
Zanav Home Collection Versus. The Joint Commissioner of Income Tax Bangalore.
Deduction on account of bad debts written off u/s. 36(1)(vii) denied - Held that - Considering the accounting principles described it cannot be the legislative intent of section 36(1)(vii) to mandate that the debit to the profit and loss account be i.....
2015 (1) TMI 1156 - ITAT DELHI
M/s Convergys Customer Management Group Inc. C/o Price Waterhouse Coopers Pvt. Ltd. Versus ACIT, Circle 1(1) International Taxn New Delhi
Transfer pricing adjustment - attribution of profits to the Permanent Establishment - India-USA DTAA - Held that - Ld.CIT(A) s order on the proposition of PE deserves to be upheld. The employees of the assessee frequently visited the premises of CIS .....
2015 (4) TMI 579 - ITAT AHMEDABAD
ITO. (International Taxation) Versus M/s. Heubach Colour Pvt. Ltd.
Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - Liable for TDS u/s 195 of the Income Tax Act,1961 - Seller transferred entire right, title,interest and ownership of the asset - Held tha.....
2015 (1) TMI 1106 - ITAT LUCKNOW
Dy. CIT-II, Kanpur Versus Shri. Sanjiv Gupta, Prop. M/s Divya International
Non-deduction of TDS on payment of commission to Foreign Agent - CIT(A) deleted the addition - Held that - The income of the non-resident was not chargeable to tax in India since the same was neither received in India nor had it accrued or deemed to .....
2015 (1) TMI 553 - ITAT PANAJI
Asst. Commissioner of Income Tax Versus M/s. Indian Furniture Products Limited.
Disallowances u/s 40(a)(ia) - non deduction of tax at source u/s 195(1) on usance charges paid to a non resident through an intermediatory bank - whether the Assessee was bound to deduct TDS u/s 195(1) in respect of usance charges paid by the Assesse.....
2015 (4) TMI 724 - ITAT PUNE
Kirloskar Proprietary Ltd. Versus The Deputy Commissioner of Income Tax, Circle-11(1), Pune
Disallowance of Payment made to Sabaand Co. on account of non deduction of Tax at Source towards legaland professional fees - income not chargeable to tax India - Held that - We have perused the material on record alongwith the order of the tax autho.....
2015 (1) TMI 1018 - ITAT BANGALORE
M/s. Vodafone South Limited Versus Dy. Director of Income Tax (International Taxation) Circle 1(1) Bangalore
Non deduction of tax at source on IUC payments made to non resident telecom operators and capacity transfer payments made to Belgacom - according to the assessee the order is barred by limitation, because the proceedings u/s 201 of the Act for assess.....
2015 (1) TMI 469 - ITAT JABALPUR
Birla Corporation Limited Versus Assistant Commissioner of Income Tax (TDS) Jabalpur
Non deduction of tax at source - TDS u/s 195 on foreign remittances - whether part of the consideration for purchases of plant, machinery or equipment can be attributed to the installation, commissioning or assembly of the plant and equipment, or any.....
2014 (12) TMI 761 - ITAT MUMBAI
Morgan Stanley International Incorporated C/o. BSR & Co. Chartered Accounts Versus Dy. Director of Income Tax
Reimbursement of salary cost treated as fees for technical services Royalty u/s 9(1)(vii) Article 12 of Indo-US DTAA - Whether the payment received by the assessee on account of reimbursement of cost of salary paid to the Seconded employee, constitut.....
2014 (11) TMI 847 - ITAT LUCKNOW
Dy. CIT. -VI, Kanpur Versus M/s. MKU (Armours) Pvt. Ltd.
Violation of Rule 46A Admission of additional evidences without providing opportunity to heard or not - Held that - CIT(A) noted that the assessee has filed an affidavit dated 11/06/2010, sworn by Mr. Manish Khandelwal, Director of the assessee compa.....