ADIT v. Epcos AG

28 SOT 412Income Tax Appellate Tribunal2009#17498 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 359,850 Indian tax judgments — from 2017 to 2017.

Judgments citing ADIT v. Epcos AG

DCIT, Chennai vs. Hyundai Motors India Ltd., Kancheepuram

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

ITA 761/CHNY/2016[2011-2012]Status: DisposedITAT Chennai27 Apr 2017AY 2011-2012
Section 143(3)Section 253(4)

…he PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench in the case of ADIT Vs Epcos AG [(2009) 28 SOT 412 (Pune)]: It is also important to bear in mind that a non-resident company having a PE in India, by itself, does not lead to taxability in India; there must be some profit attributable to such a PE which alone could be taxed in India because of the existence of the PE. When the PE carries on an activity which does not serve overall purpose of the f…

DCIT, Chennai vs. Hyundai Motor India Ltd., Kancheepuram

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

ITA 614/CHNY/2015[2010-11]Status: DisposedITAT Chennai27 Apr 2017AY 2010-11
Section 143(3)Section 253(4)

…he PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench in the case of ADIT Vs Epcos AG [(2009) 28 SOT 412 (Pune)]: It is also important to bear in mind that a non-resident company having a PE in India, by itself, does not lead to taxability in India; there must be some profit attributable to such a PE which alone could be taxed in India because of the existence of the PE. When the PE carries on an activity which does not serve overall purpose of the f…

Hyundai Motor India Limited, Kancheepuram vs. DCIT, Chennai

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

ITA 563/CHNY/2015[2010-11]Status: DisposedITAT Chennai27 Apr 2017AY 2010-11
Section 143(3)Section 253(4)

…he PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench in the case of ADIT Vs Epcos AG [(2009) 28 SOT 412 (Pune)]: It is also important to bear in mind that a non-resident company having a PE in India, by itself, does not lead to taxability in India; there must be some profit attributable to such a PE which alone could be taxed in India because of the existence of the PE. When the PE carries on an activity which does not serve overall purpose of the f…

Hyundai Motor India Limited, Kancheepuram vs. DCIT, Chennai

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

ITA 853/CHNY/2014[2009-10]Status: DisposedITAT Chennai27 Apr 2017AY 2009-10
Section 143(3)Section 253(4)

…he PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench in the case of ADIT Vs Epcos AG [(2009) 28 SOT 412 (Pune)]: It is also important to bear in mind that a non-resident company having a PE in India, by itself, does not lead to taxability in India; there must be some profit attributable to such a PE which alone could be taxed in India because of the existence of the PE. When the PE carries on an activity which does not serve overall purpose of the f…

DCIT, Chennai vs. Hyundai Motor India Limited, Kancheepuram

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

ITA 739/CHNY/2014[2009-10]Status: DisposedITAT Chennai27 Apr 2017AY 2009-10
Section 143(3)Section 253(4)

…he PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench in the case of ADIT Vs Epcos AG [(2009) 28 SOT 412 (Pune)]: It is also important to bear in mind that a non-resident company having a PE in India, by itself, does not lead to taxability in India; there must be some profit attributable to such a PE which alone could be taxed in India because of the existence of the PE. When the PE carries on an activity which does not serve overall purpose of the f…

ADIT v. Epcos AG (28 SOT 412) — Cited in 5 Judgments | BharatTax