2015 (2) TMI 394 - ITAT CHENNAI
Deputy Commissioner of Income Tax Versus M/s. International Flavours & Fragrances (I) P. Ltd.
Depreciation @ 60% on UPS treating it as part of computers - Held that:- Following the order of the Chennai Bench of the Tribunal in the case Sundaram Asset Management vs. DCIT [2014 (2) TMI 224 - ITAT CHENNAI], we hereby hold that UPS is to be treat ......
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 ......
2015 (1) TMI 1162 - BOMBAY HIGH COURT
Tao Publishing (P.) Ltd. Versus Deputy Commissioner of Income-tax, Circle-7, Pune
Reopening of assessment - proceedings are sought to be initiated after the period of four years from the end of relevant Assessment Year - As the provisions of 195 of the IT Act is very clear the amount of ₹ 1064281/- required to be disallowed ......
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 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 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 (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 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 ......
2015 (1) TMI 356 - ITAT LUCKNOW
Dy. CIT., Central Circle-2, Kanpur Versus M/s. Kothari Food & Fragrances
TDS u/s 195 - Discount allowed on sales in the nature of payment of interest or not – Invocation of section 195 r.w section 40(a)(ia) or not – payment to non-residents towards advance payment – Held that:- As per purchase contract dated 16th May, 200 ......
2015 (1) TMI 311 - ITAT CHENNAI
Deputy Commissioner of Income-tax, Chennai Versus Rane (Madras) Ltd.
TDS u/s 195 - Disallowance under section 40(a)(i) - overseas agencies commission paid to non-residents without deduction of tax at source - Held that:- From the scope of services of the agreement, we do not find any managerial/technical services are ......
2014 (12) TMI 1062 - ITAT BANGALORE
The Income Tax Officer, Ward 11(1), Bangalore Versus M/s. Clear Water Technology Services Pvt. Ltd.,
Allowability of deduction u/s 10B – Set off of brought forward business losses against the profits of the year – Effect of amendment u/s 10B w.e.f. 1.4.2001 - Whether the provisions of Sec.10B of the Act are deduction provisions or exemption provisio ......
2014 (12) TMI 887 - ITAT PUNE
Finoram Sheets Ltd Versus ITO, ward 5 (1), Pune
Remittances to foreign collaborator - Requirement to deduct TDS - Whether the assessee is liable to deduct tax at source u/s 195(1) of the Act in respect of the Design engineering fee, commercial services and other know-how contained in the Technolog ......
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 (12) TMI 430 - ITAT CHENNAI
The Income Tax Officer (International Taxation) -II Chennai Versus M/s FL Smidth Ltd
Deletion of demand u/s 201(1) and 201(1A) - Liability to Deduct tax on remittance made to its Denish group concern – Remittance made attract Provisions u/s 9(1)(vi) relating to Royalty or not - whether the assessee’s act of acquiring ‘2003 Microsoft ......