2015 (6) TMI 419 - ITAT MUMBAI
Idea Cellular Limited Versus Asst. Director of Income Tax (International Taxation) – 3 (1) , Mumbai
TDS liability u/s 195 - Payment towards Arranger s fee payable to HSBC, Hongkong - whether such a fees paid to the arranger can be termed as interest within the meaning of section 2(28A) or fees for technical services for service within the meaning o.....
2015 (6) TMI 680 - BOMBAY HIGH COURT
Commissioner of Income Tax-4 Versus M/s. Prime Broking Co. (I) Ltd.
Disallowance under Section 40(a)(ia) - rent payment made without deduction of TDS - ITAT deleted the addition - Held that - Commissioner of Income Tax (Appeals) as well as the Tribunal has reached a concurrent finding of fact that the payment made by.....
2015 (6) TMI 211 - ITAT HYDERABAD
The Asst. Director of Income Tax (Intl. Taxn) -I, Hyderabad Versus M/s. Locuz Enterprise Solutions Ltd.
Deduction of tax at source u/s. 195 - whether payment made by assessee to the foreign company being in the nature of royalty ? - CIT(A)deleting the demand raised u/s. 201(1) and 201(1A) - Held that - When the department has not been able to bring any.....
2015 (6) TMI 459 - ITAT HYDERABAD
The Asst. Director of Income Tax (Intl. Taxn) -I, HYDERABAD and others Versus M/s. Locuz Enterprise Solutions Ltd., HYDERABAD
Non deduction of TDS u/s. 195 demand raised u/s. 201(1) and 201(1A) - whether payment made by assessee to the foreign company not being in the nature of royalty ? - CIT(A) deleted disallowance made u/s. 40(a)(i) - Held that - On going through the fac.....
2015 (5) TMI 873 - DELHI HIGH COURT
Director of Income Tax- Delhi Versus M/s. Lufthansa Cargo India
Liability to deduct tds - agreements between the assessee and non-residents are not fee for technical services within the meaning of Section 9(1)(vii) so as to oblige the assessee to deduct tax at source under Section 195 as held by ITAT - Held that .....
2015 (5) TMI 852 - ITAT DELHI
Mitsubishi Corporation India Private Limited Versus DCIT, Circle 16 (2) , New Delhi
Transfer pricing adjustment - addition on Service fee received - Held that - The assessee simply rendered agency services under this segment by co-ordinating between customers and its AEs. By no standard, the assessee can be said to have dealt with t.....
2015 (5) TMI 820 - ITAT DELHI
Nokia India Pvt. Ltd. Versus Dy. Director of Income-tax, Cir. 2 (1) , International Taxation, New Delhi.
Remittances made by NIPL to Nokia Corporation for software downloads are sums chargeable to Tax as laid down in S 195 - whether NIPL can be held to be an assessee in default for non-deduction of tax thereon as per law - validity of survey - denial of.....
2015 (7) TMI 39 - ITAT MUMBAI
Mashreq Bank psc Versus The Joint Director of Income-tax (International Taxation) -3 (1) , Mumbai
Restricting the deduction for Head Office Expenses (HOE) - DTAA with U.A.E. - AO denied the treaty benefit to the assessee for the reason that it had not paid tax in UAE - Held that - Firstly,in the assessment year involved, limitation clause of appl.....
2015 (5) TMI 715 - ITAT DELHI
ACIT Circle-9 (1) , New Delhi Versus M/s SRL Ranbaxy Ltd (Now Known As Super Religare Laboratories Ltd) And Others
Addition made by the AO u/s. 40(a)(i) - CIT(A) restricted disallowance - Held that - The working submitted by the assessee show that the amount of discount given to the Collection Centre is ₹ 11,78,24,030/- as against the disallowance of ₹.....
2015 (6) TMI 602 - ITAT HYDERABAD
CYIENT Ltd. Versus Deputy Commissioner of Income-tax Officer, Circle -2 (1) , Hyderabad
Disallowance of payment towards consultancy charges by determining Arm s Length Price (ALP) at Nil - Held that - In the instant case, the UK and USA subsidiaries did only contractual work parcelled out to it whose results were given to clients direct.....
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 278 - GUJARAT HIGH COURT
SAI CONSULTING ENGINEERS PVT LTD Versus DEPUTY COMMISSIONER OF INCOME TAX - CIRCLE 4 (1)
Reopening of assessment - non deduction of tds under section 195, thus disallowance u/s 40(a)(i) - Held that - Specific questions were asked by the Assessing Officer regarding the expenditure in foreign currency, which shall be inclusive of the amoun.....
2015 (6) TMI 901 - ITAT AHMEDABAD
ABM Steels Pvt. Ltd. Versus ACIT
Disallowance of building repair expenses - revenue v/s capital - Held that - The assessee has only replastered, re-furnished and re-plumbered its factory building. This is not the Revenue s case that the same has caused any increase in capacity of th.....
2015 (5) TMI 609 - ITAT HYDERABAD
M/s. Ushodaya Enterprises Private Limited Versus Asstt. Commissioner of Income-tax
TDS liability under S.194J in respect of payments made to news service agencies - Held that - Issue is covered by the decision of the Tribunal in assessee s own case for assessment years 2004-05 to 2006-07 2012 (7) TMI 120 - ITAT HYDERABAD against th.....
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.....