ABC International Inc., In re
Duty of non-resident-Duty to file return of income-The liability to i9ncome tax was warded off by provision of DTAA. The non resident applicant was liable to file return under s.139(1)
S.139(1) of [LexDoc Id : 410280]
AAR
2011
Goodyear Tire and Rubber Co., In re
Transfer to subsidiary - without consideration-'ALP' and Gift-When the shares of an Indian companies were transfered to 100% subsidiary without consideration neither S.92C nor S. 56(2) (viia) was applicable.
[LexDoc Id : 408789]
CIT vs Ravi Rajagopal
Income deemed to accrue in India-Dependent Personal Services-A.Y. 2001-02.
The assessee was employee of a U.K. company. A part salary was paid to him thru Indian subsidiary in India. The payment received in [LexDoc Id : 410439]
HC (Chennai)
2011
DHL Express India (P) Ltd. vs ACIT
Computation of: ALP-Courier service- Operational income, Resjudicata- Comparable cases-A.Y.2006-2007. The assesee was in the courier service inside as well as outside India.
Operational income. The bad debts recovered, E-mail charge [LexDoc Id : 408788]
ITAT (Mumbai)
2011
Areva T and D, SA vs ADIT and Ors.
Validity of Re-asstt. - Non-resident's case-No return filed-A.Y. 2005-06.
The non-resident assessee had not filed any return of income. Only a certificate u/s 197(1) was issued. The notice u/s 148 was issu [LexDoc Id : 408347]
ED vs M. Shamba Shiva Rao
Power to summon persons to give evidence and produce documents-Acquittal upheld-Before a person could be held to be guilty of disobeying the summons, the summons should be served on him and he should have wilfully disobeyed the su [LexDoc Id : 410597]
Thirumalai Chemicals Ltd. vs UOI and Ors.
Appeal to Appellate Tribunal-Procedure prescribed by FEMA-The Supreme Court, on the question whether the tribunal was justified in dismissing the appeals preferred under s.19(1) of the Foreign Exchange Manage [LexDoc Id : 410951]
G.D. Metsteel (P) Ltd. vs ACIT
Expenses to earn exempt income-Investment in Shares from awn funds-Ay-2005-2006. The assessee had invested in shares form it’s awn funds in earlier year. No part of interest payment on funds borrowed for business duri [LexDoc Id : 413240]
CIT vs Oracle India (P) Ltd.
Arm’s length price- (ALP)-Royalty paid to parent company. Royalty paid under sub-license-Ay-1999-2000 to 2001-2002. The assessee was a 100% subsidiary of a u.s. company ‘OCL’. It imported master- copies of software from OCL and then duplic [LexDoc Id : 410177]
D.B. Zwirn Mauritius Trading No. 2 Ltd., In re
Income deemed to accrue in India-Capital gains : Sale of shares of Indian company-The applicant was a Mauritian company. It sold shares of Indian company to another Mauritian company. The capital gains arose in mauritius and not in [LexDoc Id : 409690]
