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Documents Found: 294 |
Title |
Forum |
Year |
ADIT vs Warner Brother Pictures Inc.
Income deemed to accrue in India-Distribution of films v. Royalty, Business income-Ay-2006-2007. The assessee was a non-resident company. It’s business was production and distribution of films. It granted exclusive distribution right [LexDoc Id : 424068]
|
ITAT (Mumbai) |
2011 |
Annapurna Business Solutions vs ACIT
[LexDoc Id : 428649]
|
ITAT (Hyderabad) |
2011 |
Tevapharm (P) Ltd. vs ACIT
[LexDoc Id : 429198]
|
ITAT (Mumbai) |
2011 |
Hindalco Industries Ltd. vs Addl. CIT
Maintainability of Writ - Alternate remedy-Reference to TPO-The A.O. had made reference to the TPO as per CBDT's Instructions and after taking approval of CIT. There was an alternate remedy u/s 144C and u/s 253 [LexDoc Id : 428688]
|
HC (Bombay) |
2011 |
Metal One Corpn. vs DDIT
Stay of Demand- Debatable issue-Bona fide dispute - Controversy as to PE-Ay- 2008-09. The assessee was a Japanese Company. It was trading in steel products. It opened a liason office in India which was treated as it’s PE by [LexDoc Id : 424994]
|
ITAT (Delhi) |
2011 |
Phoenix Mecano India Ltd. vs DCIT
Computation of: ALP-Margin of tolerance - Law applicable-Ay- 2007-08. There was a fall in g. p. rate of about 5% when compared with last year.
The adjustments in ALP were to be made only in regard to [LexDoc Id : 424988]
|
ITAT (Mumbai) |
2011 |
Kuehne + Nagel (P) Ltd. vs ACIT
ALP- C & F Agent. / C&F Agent & ALP-Comparable instances Rule of consistency-Ay- 06-07. The assessee was an international C&F agent. It did not own trucks, airplanes or such other transportation assets.
The TPO chose cer [LexDoc Id : 424986]
|
ITAT (Delhi) |
2011 |
DIT vs Ericsson A.B., Ericsson Radio System A.B. and Metapath Software International Ltd.
Business connection-Supply of GMS cellular equipments-Ay- 1997-98. The assessee a company of Sweden sold hardware and software (GSM) to an Indian cellular operator. Property in goods passed abroad. The eq [LexDoc Id : 421206]
|
HC (Delhi) |
2011 |
Tata Communications Ltd. vs Addl. CIT
[LexDoc Id : 423861]
|
ITAT (Mumbai) |
2011 |
Nuclear Power Corpn. of India Ltd., In re
Pendency of proceedings-Question of taxability-The A.O. had held that the gains arising out of impugned deal were taxable as per S. 44BBB. The other party had filed an appeal. The question raised i [LexDoc Id : 423168]
|
AAR |
2011 |
Shell Technology India (P) Ltd., In re
Fees for technical services [FTS]-Back- office services by Branch Treaty/ DTAA applicable-The applicant was an Indian company. A Dutch company provided it with back-office services for accounts thru it’s branch in Philippines. The applicabl [LexDoc Id : 423167]
|
AAR |
2011 |
Bayer Material Science (P) Ltd. vs Addl. CIT
[LexDoc Id : 430269]
|
ITAT (Mumbai) |
2011 |
V. Bhaskaran vs Special Director of Enforcement
Foreign Exchange Regulation Act 1973: Reasonable opportunity to delinquent before instituting adjudication-Five days afforded in opportunity notice not bereft of opportunity to delinquent-The provisions of s.51 of the Foreign Exchange Regulation Act 1973 contemplated reasonable opportunity to be afforded to the delinquent before institu [LexDoc Id : 425001]
|
HC (Chennai) |
2011 |
DCIT vs Sona Okegawa Precision Forgings Ltd.
Determination of ALP – Payment of Royalty-Onus of TPO-Discharge of onus-Ay- 2005-06. The assessee a manufacturer of auto-parts paid royalty at 3% on domestic & export sales to an ‘AE’. In absence of any material to the con [LexDoc Id : 424990]
|
ITAT (Delhi) |
2011 |
McDonald's India (P) Ltd. vs DCIT
Reference to TPO-Law applicable-The provisions of S.92CA(2A), empowering TPO to consider transactions not refund to were operative w.e.f. 1.6.2011 and will not apply to AY- 2002-03.< [LexDoc Id : 423996]
|
ITAT (Delhi) |
2011 |
Sona Okegawa Precision Forgings Ltd. vs Addl. CIT
Alp: Computation of-Control manufacturer-Ay-2006-2007. Only a fraction of the goods manufactured by assessee were sold to AEs. Bulk sales were to unrelated parties. It was not a contract manu [LexDoc Id : 423877]
|
ITAT (Delhi) |
2011 |
Aithent Technologies (P) Ltd. vs ITO
[LexDoc Id : 427153]
|
ITAT (Delhi) |
2011 |
Perfetti Van Melle Holding B.V., In re
Fees for technical services-Service specific to industry, Service specific to confectionery industry-The Applicant is a Duty company. It entered into an agreement with one of it’s ground company ‘PI’ for providing operation & support services specific [LexDoc Id : 423159]
|
AAR |
2011 |
Spacewood Furnishers (P) Ltd., Kirit Sharad Joshi and Vivek Moreshwar Deshpande vs Director General of Income-tax, DIT, ADIT and DCIT
Validity of: Search-Non-Application of mind by D.G.-The D.G. of Income Tax had approved the search merely on basis of satisfaction notes filed by A.D.I. & Addl. D.I. The notes do not indicate any discre [LexDoc Id : 420704]
|
HC (Bombay) |
2011 |
Poonawalla Aviation (P) Ltd., In re
DTAA - Applicable DTAA-MOST Favoured Nation clause (M.F.N.)-The applicant was to pay interest to an Indian company, a French company and to assignee French company.
Interest Insured by COFACE
T [LexDoc Id : 423160]
|
AAR |
2011 |
Iljin Automotive (P) Ltd. vs ACIT
[LexDoc Id : 430293]
|
ITAT (Chennai) |
2011 |
Benetton India (P) Ltd. vs ITO
[LexDoc Id : 427030]
|
ITAT (Delhi) |
2011 |
ACIT vs Lafarge India (P) Ltd.
[LexDoc Id : 422088]
|
ITAT (Mumbai) |
2011 |
Ketan V. Parekh and Panther Fincap and Management Services Ltd. vs ED and Anr.
Imposition of penalty for violation of s.3(d) and s.6(3)(e)of FEMA 1999: Tribunal’s direction to deposit 50 percent of penalty amount-Non-mention in applications for condonation of delay that remedy prosecuted before a wrong forumwith due diligence and in good faith, Sole object to delay compliance with tribunal’s direction, Order dismissing applications upheld-Penalty for violation ofs.3(d) and s.6(3)(e) of the Foreign Exchange Management Act 1999 was imposed on the appellants. On appeal, the tribunal direct [LexDoc Id : 419954]
|
SC |
2011 |
International Global Networks BV vs DDIT
Validity of re-asstt.-Head of income-The A.O. had accepted after due application of mind that interest on refund was covered under Art.11. The notice u/s 148 to bring it under Art.7 was n [LexDoc Id : 425992]
|
ITAT (Mumbai) |
2011 |
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