Tax Management India .com TMI - Tax Management India. Com   
 

Income Tax Case Laws - Section: 9

 
Filter:
Cases for Section: 9
Showing 1 to 15 of 967 Records
 

2015 (5) TMI 726 - ITAT DELHI

Aspect Software Inc. Versus ADIT, Circle 1 (1) , International Taxation, New Delhi

Revenue earned from supply of software taxed as Royalty - DTAA between India and USA - Held that - Respectfully following the decision of Ericsson A.B. (2011 (12) TMI 91 - Delhi High Court) and Infrasoft Ltd. (supra), we hold that the consideration r.....

2015 (5) TMI 681 - ITAT DELHI

Delta Air Lines, Inc. C/o BMR and Associates LLP Versus Asstt. Director of Income Tax (International Tax)

Denial of benefit of Article 8 of India-USA Double Taxation Avoidance Agreement - Held that - Arrangement of pool requires several persons coming together to contribute and combine their resources for a large business and then share the resources amo.....

2015 (5) TMI 277 - BOMBAY HIGH COURT

Director of Income Tax (IT) II, Mumbai Versus M/s. B4U International Holdings Limited,

Permanent establishment - business of telecasting of TV channels such as B4U Music, MCM etc - Dependent agent of assessee - AO observed that affiliated entities of the assessee are basically an extension in India and constitute a permanent establishm.....

2015 (5) TMI 235 - BOMBAY HIGH COURT

Director of Income Tax (IT) -I Versus AP. Moller Maersk A/S. C/o. Maersk Line India Pvt. Ltd.

Consideration / fees for technical services - AO held that the amounts paid by the three agents to the assessee taxable in India under Article 13(4) of the DTAA and assessed tax at 20 under section 115A - Tribunal allowed the appeal of the assessee H.....

2015 (5) TMI 307 - ITAT DELHI

M/s Reebok India Company Versus DCIT

Transfer Pricing Adjustment on AMP Expenses - Whether the Income Tax Appellate Tribunal was right in distinguishing and directing that selling expenses in the nature of trade/volume discounts, rebates and commission paid to retailers/dealers etc. can.....

2015 (4) TMI 845 - ALLAHABAD HIGH COURT

The Principal Officer, LG Electronics Pvt. Ltd. Versus Asst. Commissioner of Income Tax And Another

Reopening of assessment - non stating any failure on the part of the assessee to disclose complete and full facts/concealment of facts is bad as submitted by assessee - Held that - It is in respect of items mentioned at serial no. 2 i.e. payments mad.....

2015 (5) TMI 584 - ITAT MUMBAI

Perma Pipe India Pvt. Ltd. Versus Dy. Commissioner of Income Tax

Disallowance of claim of royalty payment - Revenue or capital expenditure - payment made by the assessee in pursuance of the agreement entered by the assessee with PPME - Held that - In the instant case, the duration of the agreement was utmost for t.....

2015 (5) TMI 582 - ITAT DELHI

Additional Director of Income Tax (International Taxation) Versus Baker Hughes Singapore Pte Ltd

Applicability of provisions of section 44BB - interpretation of the legislative intent behind the scheme of taxation envisaged in 9(1)(vii) rw 44DA and 44BB - whether the provisions of Section 44BB will apply to the facts or whether Section 44DA will.....

2015 (5) TMI 583 - ITAT DELHI

Additional Director of Income Tax (International Taxation) Versus Baker Hughes Singapore Pte Ltd

Applicability of provisions of section 44BB - interpretation of the legislative intent behind the scheme of taxation envisaged in 9(1)(vii) rw 44DA and 44BB - whether the provisions of Section 44BB will apply to the facts or whether Section 44DA will.....

2015 (5) TMI 573 - ITAT PUNE

The Dy. Director of Income Tax Versus iGATE Computer Systems Ltd., (formerly known as Patni Computer Systems Limited)

Payment made for transfer of user rights of software - whether the same are taxable as royalty under Article 12/13 of Double Taxation Avoidance Agreement (DTAA) between India and USA/UK/Singapore - non-deduction of tax at source - whether the assesse.....

2015 (5) TMI 345 - ITAT BANGALORE

Asst. Director of Income Tax, (International Taxation) Versus M/s. Tesco International Sourcing Ltd.

Entitlement to the benefit granted under Section 9(1)(i) - procurement of goods for the purpose of exports - Assessing Officer treating the Tesco International Sourcing Limited - India Liaison Office as PE of the assessee - Held that - Respectfully f.....

2015 (5) TMI 607 - ITAT DELHI

JC Bamford Investments Rocester Versus Additional Director of Income Tax

Existence of Permanent Establishment (PE) in India or not - India UK DTAA - Held that - All the requisite conditions for attracting the mandate of Article 5(2)(k) are satisfied inasmuch as (i) there is furnishing of services including managerial serv.....

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 (5) TMI 760 - ITAT MUMBAI

ADIT (IT) -1 (2) , and DDIT (IT) -1 (2) , Mumbai Versus Co-operative Centrale Raiffeisen

Permanent establishment (PE) of the assessee in India - whether receipts on account of advisory services and guarantee commission had to be assessed in India? - Whether particular articles of the Agreement of the Avoidance of Double Taxation between .....

2015 (4) TMI 301 - UTTARAKHAND HIGH COURT

M/s Fugro Geoteam AS Versus The Additional Director of Income-tax, International Taxation, Dehradun

Fees from technical services - assessee is foreign company incorporated under the laws of Norway engaged in the activities relating to acquisition of 3D sesismic data under contracts with Reliance Industries Ltd. and ONGC - Tribunal held that the mob.....

 
   
 
 
1....
 
what is new what is new





© Taxmanagementindia.com [A unit of MS Knowledge Processing Pvt. Ltd.] All rights reserved.