UPS Worldwide Forwarding Inc vs UPS Jetair Express (P) Ltd. and Ors.
Double Taxation Relief - Application for not deducting tax at source-Pendency under: Mutual Agreement Procedure-The proceedings under Mutual Agreement Procedure were pending. A memo of understanding was reached between USA and India to defer assessment and suspe [LexDoc Id : 456437]
Motorola Solutions India (P) Ltd. vs CIT and Ors.
Validity of: Garnishee proceedings-Proceedings of MAP pending - Bank guarantee given-A.Y. 2005-06.
The proceedings under MAP as per DTAA were pending. The bank guarantee was renewed for a period of 3 years. The action u/s 226(3) i [LexDoc Id : 452267]
HC (Punjab and Haryana)
2013
Poompuhar Shipping Corpn. Ltd. and Ors. vs ITO and Ors.
Penalty/Interest for not deducting tax at source-Status of the deductor-assessee-A.Y. 2002-03, 2006-07.
The status of the assessee as an agent of the non-resident was not relevant for proceedings u/s 201(1) and u/s 201(1A). Th [LexDoc Id : 452241]
HC (Chennai)
2013
Cairn UK Holdinngs Ltd. vs DIT
Rate of: Capital Gains Tax-Sale of equity - shares by a Non-resident-The assessee was a non-resident. The capital gains tax on sale of share was 10% as per proviso to S. 112(1) r.w. proviso I to S. 48. The fact that pro [LexDoc Id : 452825]
Credit Lyonnais vs ADIT
Non-discrimination-Rate of tax applicable-A.Y. 2002-03, 2003-04.
The business income of a non resident co. taxable at rate applicable to a foreign co as per Finance Act and not at rate of [LexDoc Id : 457419]
ITAT (Mumbai)
2013
CIT vs Reliance Energy Ltd.
Interest chargeable on excess refund-Law applicable-
A.Y. 1998-99.
The Expln. 2 to S. 234D inserted w.r.e.f 1.6.2003 by the Finance Act, 2012 was not applicable where the asst. was completed befor [LexDoc Id : 450388]
US Technology Resources (P) Ltd. vs ACIT
F.T.S.-Technical Service: Financial risk management. Training to employee-A.Y. 2007-08.
The assessee obtained assistance from a co. of USA as assistance reg: Financial risk management. The said co. also provided trainin [LexDoc Id : 453895]
Sandvik Asia (P) Ltd. vs ACIT
Comparable for ALP-Rule of consistency-The comparables earlier accepted as functionally comparable in two years could not be held to be not comparable in current year without any change in [LexDoc Id : 452434]
