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Forex - Judgement
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Documents Found: 279   
Title Forum  Year
SmithKline Beecham Port Louis Ltd., In re Capital Gains - Mauritian Co.-Sale of shares of Indian Co. - Capital Gains and ALP-The applicant was a co. of Mauritius. It held shares of Indian co. as investment since 1996. It proposes to sell those shares to a group co. The long [LexDoc Id : 433099]
AAR 2012
Netapp B.V. and Sin Oceanic Shipping ASA vs Authority for Advance Rulings and Ors. Maintainability of: Application for advance ruling-Pendency of Proceeding - Pending Return of Income-The return filed by the Applicant was pending. There was proceeding pending. The application was hit by the bar u/s 245(12) proviso.
S. Proviso t [LexDoc Id : 435132]
HC (Delhi) 2012
Castleton Investment Ltd., In re Capital Gains - Sale of Shares of Indian Co.-Treaty shopping-off market transactions-The applicant is a co. incorporated in Mauritius. It proposes to sell it's shares in an Indian co. Which were held as investment. It is the legal and [LexDoc Id : 432757]
AAR 2012
Orient Green Power Pte Ltd., In re Powers of AAR-Power to decline Ruling - The AAR has the power to consider the facts and law-The applicant had transferred shares of an Indian co. to another Indian co. without consideration. It was not shown that transfer was effected as per [LexDoc Id : 432756]
AAR 2012
Orient Green Power Pte. Ltd., In re Power of AAR-Power to Decline a Ruling-The AAR could decline a ruling where adequate materials were not placed before it, even if it had earlier admitted the application.
S. 245R(2)(ii [LexDoc Id : 432415]
AAR 2012
De Beers U.K. Ltd. vs DDIT Interest - Non payment of advance-tax-Entire income subject to TDS-No interest u/s 234B could be charged on where tax was deductible at source, on entire income.
S. 234B of the Income Tax Act, 1961.
[Edit [LexDoc Id : 434091]
ITAT (Mumbai) 2012
Grasim Industries Ltd. vs DCIT [LexDoc Id : 432830]
ITAT (Mumbai) 2012
WNS Global Services (P) Ltd. vs ITO [LexDoc Id : 431536]
ITAT (Mumbai) 2012
JCIT vs American Express Bank Ltd. [LexDoc Id : 435241]
ITAT (Mumbai) 2012
Spectrum Geo Ltd., In re Fees for Technical Services (FTS)-Processing Seismic Data-A.Y. 2009-10, 10-11.
The ONGC had awarded the contract to a UAE Co. for undertaking seismic survey of River basins. The UAE Co. collected the dat [LexDoc Id : 432349]
AAR 2012
M-1 Overseas Ltd., In re Exploration etc. of mineral oil-Mud engineering - FTS-The applicant is a co. incorporated in Cayman Islands. The applicant contracted with an Indian co. 'IC' for providing mud lab and operating personnel [LexDoc Id : 432348]
AAR 2012
Dresser Rand India (P) Ltd. vs DCIT Business expenditure-Repairs - Onus on assessee-The assessee did not prove that expenditure incurred on repairs did not result in acquiring a new capital asset. The A.O. could disallow it as capital [LexDoc Id : 438301]
ITAT (Mumbai) 2012
DDIT vs M. Fabricant and Sons Inc. [LexDoc Id : 435653]
ITAT (Mumbai) 2012
DDIT vs M. Fabricant and Sons Inc. PE-Liason office vis-à-vis PE - Liason office for purchase of goods-A.Y. 2006-07, 07-08.
The assessee was a co. of USA dealing in cut and polished diamonds. It had a liason office in India, for co-ordination of pu [LexDoc Id : 434740]
ITAT (Mumbai) 2012
Moody's Analytics Inc., In re

Moody's Group Cyprus Ltd., In re

Copal Research Ltd., In re

Copal Market Research Ltd., In re
Residential status of a company-Place of management-The Mauritian Co. CRL sold shares of an Indian Co. to a Co. of Cyprus and CMRL another Co. of Mauritius sold shares of a U.S. Co. to another U.S. Co. [LexDoc Id : 433094]
AAR 2012
C.A.T. Geondata GMBH, In re PE-Sub-Contractor-The applicant conceded the it's sub-contractor in India was it's PE. The business income attributable to the PE was taxable in India.
Art. 5(3), [LexDoc Id : 432347]
AAR 2012
Columbia Sportswear Co. vs DIT Maintainability of SLP- Conditions-Substantial question of law-Unless the petition raises a substantial question of law or is of general importance or a similar question is already pending before it, the Supreme C [LexDoc Id : 429517]
SC 2012
Credit Suisse (Singapore) Ltd. vs ADIT Capital Gains/Capital Receipt-Gains on cancellation of forward contracts in foreign exchange-A.Y. 2007-08.
The assessee is a Co. of Singapore. It is in portfolio investment in Indian securities and is registered with SEBI.
The gains [LexDoc Id : 434090]
ITAT (Mumbai) 2012
Emirates Shipping Line, FZE vs ADIT Validity of: Re asstt. of Non-resident-Liable to tax - DTAA v. Act-The expression "liable to tax" in the DTAA does not mean actually taxed in it's own country.
The non-resident was not assessable to tax in India [LexDoc Id : 433574]
HC (Delhi) 2012
DDIT vs Mizuho Corporate Bank Ltd. Income deemed to accrue in India-Interest paid by Indian branch to Head office-A.Y. 2004-05.
The interest paid by Indian branch to it's overseas H.O. was not assessable in India.
S. 195 was in applicable.
S. 9(1)(i [LexDoc Id : 434741]
ITAT (Mumbai) 2012
Rashid Kapadia vs Medha Gadgil and Ors. [LexDoc Id : 429206]
SC 2012
Ericsson AB vs DDIT [LexDoc Id : 435544]
HC (Delhi) 2012
Abu Dhabi Commercial Bank Ltd. vs Addl. DIT

Addl. DIT vs Abu Dhabi Commercial Bank Ltd.
[LexDoc Id : 435419]
ITAT (Mumbai) 2012
Abbey Business Services India (P) Ltd. vs DCIT FTS v. Reimbursement of expenses-Outsourcing Agreement-A.Y. 2005-06, 06-07.
The U.K. Company agreed with the assessee an Indian Co. for outsourcing services. The U.K. Co. also provided trained staff t [LexDoc Id : 434103]
ITAT (Bangalore) 2012
Dynamic India Fund I, In re Capital gains: Taxability under DTAA with Mauritius-Sale of shares of Indian co. by foreign co.-The applicant is a co. of Mauritius. Two of it's directors are resident of Mauritius. One is resident in India and other is resident of USA. The decis [LexDoc Id : 430829]
AAR 2012
 
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