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2019 (6) TMI 311 - HC - Income TaxInterest payable u/s 234B - Collection of interest for non-deposit of advance tax in respect of the consideration received by the non-resident assessee - payer is liable to deduct TDS on payment - PE in India - DTAA - HELD THAT:- This Court notices that for another assessment year this Court had, following its previous order in The Commissioner of Income Tax International Taxation-3 vs. Shanghai Electric Group Co. Ltd. [2018 (4) TMI 1716 - DELHI HIGH COURT] rejected the Revenue‟s appeal. Tribunal had followed the decisions of this Court in the cases of ‘Director of Income Tax vs. Jacabs Civil Incorporated’ [2010 (8) TMI 37 - DELHI HIGH COURT] , ‘Director of Income Tax, International Taxation vs. GE Packaged Power Inc. and ors.’ [2015 (1) TMI 1168 - DELHI HIGH COURT] and ‘Commissioner of Income Tax, International Taxation-2 vs. ZTE Corporation’ 2017 (1) TMI 1338 - DELHI HIGH COURT] Since the Tribunal followed the rulings of this Court no question of law arises. These appeals are dismissed as untenable along with pending applications.
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