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Director of Income Tax (International Taxation) Versus Siemens Aktiengesellschaft

2012 (11) TMI 1228 - BOMBAY HIGH COURT

Income accrued to the assessee in India in respect of supply of equipment - business connection of the assessee in India - Duty is cast on the payer to pay tax at source, on failure on the part of the payee, no interest u/s. 234B - income of the asse .....

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umar For the Respondent : P. J. Pardiwala, Sr. Advocate with Sameer Chitnis i/by Crawford Bayley & Co. ORDER Three questions of law are raised by the revenue read thus : 1) Whether on the facts and in the circumstances of the case, the ITAT was j .....

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, 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 payee, no interest u/s. 234B can be imposed on the payee assessee ignoring the fact that it is the liability of the payee to p .....

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