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Income Tax Case Laws - Section: 195

 
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Cases for Section: 195
Showing 1 to 15 of 597 Records
 

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 (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.....

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 189 - GUJARAT HIGH COURT

M/s E-INFOCHIPS LIMITED Versus DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4

Reopening of assessment - beyond the period of 4 years - Software License Fees paid to the foreign companies was in nature of Royalty and thus, Capital Expenditure and therefore, it attracts section 195 of the Income Tax Act and therefore payment mad.....

2015 (4) TMI 191 - MADRAS HIGH COURT

The Commissioner of Income Tax Versus M/s. Fluidtherm Technology Pvt. Ltd.,

Disallowance u/s 40(a)(ia)- Non deduction of TDS on export commission paid by the assessee to the non-resident - ITAT deleted the disallowance - Held that - The facts of the present case are akin to the facts of the decision in Toshoku Ltd.'s cas.....

2015 (3) TMI 939 - DELHI HIGH COURT

Agence Frances Press Versus Asst. Dirctor of Income Tax

Interest under Section 234B - non-payment of advance tax - non deduction of tds - Held that - As relying on DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION Versus GE PACKAGED POWER INC. AND OTHERS 2015 (1) TMI 1168 - DELHI HIGH COURT no interest is lev.....

2015 (3) TMI 719 - MADRAS HIGH COURT

Commissioner of Income Tax Versus M/s. Orient Express

Non deduction of tds - payments made by the assessee to the non-residents - whether the relationship between the appellant and the agents is contractual and entire service is provided outside India and duly compensated by way of commission payment wh.....

2015 (3) TMI 491 - ITAT AHMEDABAD

Gujarat State Petroleum Corporation Limited Versus JCIT

Reopening of assessment - Disallowance of claim u/s 42 - principle of merger - CIT(A) allowed part relief - Held that - In the present case, notice u/s 148 of the Act has been issued on 24.12.2008 in relation to Assessment Year 2001-02 and hence, reo.....

2015 (3) TMI 399 - ITAT BANGALORE

Zanav Home Collection Versus. The Joint Commissioner of Income Tax Bangalore.

Deduction on account of bad debts written off u/s. 36(1)(vii) denied - Held that - Considering the accounting principles described it cannot be the legislative intent of section 36(1)(vii) to mandate that the debit to the profit and loss account be i.....

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 (4) TMI 579 - ITAT AHMEDABAD

ITO. (International Taxation) Versus M/s. Heubach Colour Pvt. Ltd.

Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - Liable for TDS u/s 195 of the Income Tax Act,1961 - Seller transferred entire right, title,interest and ownership of the asset - Held tha.....

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 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.....

 
   
 
 
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