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2017 (3) TMI 1535 - HC - Income TaxTreatment of AMP expenses - whether they are to be considered as an international transaction - Royalty and technical guidance fee - whether it is revenue or capital expenditure - Held that:- the Rulings of the Income Tax Appellate Tribunal (ITAT) for the previous years have been upheld by this Court in Honda Siel Power Products Ltd. v. DCIT [2015 (12) TMI 1333 - DELHI HIGH COURT ] and CIT v. Honda Siel Power Products Ltd [2017 (5) TMI 469 - DELHI HIGH COURT]. No substantial question of law, therefore, arises on these aspects. - Decided against revenue Commission paid - whether the assessee was liable to deduct tax at source under Section 195 - Held that:- issue notice.
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