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Director of Income Tax (International Taxation) Versus Siemens Aktiengesellschaft

2012 (11) TMI 1228 - BOMBAY HIGH COURT

Income Tax Appeal No. 1033 of 2011 - Dated:- 20-11-2012 - J. P. Devadhar And M. S. Sanklecha, JJ. For the Appellant : Suresh Kumar For the Respondent : P. J. Pardiwala, Sr. Advocate with Sameer Chitnis i/by Crawford Bayley & Co. ORDER Three quest .....

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hat there existed a business connection of the assessee in India? 2) Whether on the facts and in the circumstances of the case, the ITAT was justified in holding that when duty is cast on the payer to pay tax at source, on failure on the part of the .....

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ether on the facts and in the circumstances of the case and in law the ITAT was justified in holding that the income of the assessee arising on account of Royalty and Fees for Technical Services is taxable on receipt basis and not on accrual basis as .....

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