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 ......
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 (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 (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, const ......
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 com ......
2015 (1) TMI 871 - KARNATAKA HIGH COURT
THE BANK OF TOKYO MITSUBISHI LTD Versus THE DIRECTOR OF INCOME TAX, INTERNATIONAL TAXATION, MUMBAI
Head office liability to deduct TDS - Interest payment made by the Indian Branch to its head office abroad - whether allowed as a deduction in computing the profits of the appellant’s branch in India ? - Held that:- Interpreting section 40(a)(i ) of ......
2015 (3) TMI 1052 - ITAT AHMEDABAD
The Income-tax Officer(Intl. Taxn.) Vadodara Versus M/s Denial Measurement
Non deduction of tds on technical work and related to engineering - submission of the Assessee that the Services provided by the non- resident were not in the nature of “making available” hence Article 12 of India U.S.A. treaty were not applicable - ......
2014 (11) TMI 552 - ITAT AHMEDABAD
FAG Bearings India Ltd. Versus DCIT, Ci rcle-1, Baroda
Addition of interest received on income tax refund – Held that:- As decided in assessee’s own case for the earlier assessment year, the decision in Avada Trading Co. (P.) Ltd. Versus Assistant Commissioner of Income-tax, Spl. Circle 18(1) [2006 (1) T ......
2015 (2) TMI 353 - ITAT BANGALORE
A. Mohiuddin Versus Additional Director of Income-tax (International Taxation), Mangalore
Default for not deducting the TDS while making payments to the non resident Mrs.Zohra Moidin - demand of tax against the assessees as well as interest u/s 201(1A) - Held that:- From the date of payments, parties were aware that these payments would ......