Championship Ltd. v. CIT (international

18 Taxmann.com 347Reported decision2017#17047 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 363,153 Indian tax judgments — from 2019 to 2019.

Judgments citing Championship Ltd. v. CIT (international

Ulo Systems Llc, Noida vs. DCIT (International Taxation), Dehradun

In the result appeals filed by assessee stands partly allowed as indicated above

ITA 317/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Mar 2019AY 2012-13

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2008-09 Ay: 2009-10 Ay: 2010-11 Ay: 2011-12 Ay: 2012-13 M/S Ulo Systems Llc Dcit, C/O S.R.Batliboi & Co., International Taxation Golf View Corporate Tower B Vs. Dehradun Near Dlf Golf Course Sector 42 Gurgaon 122 002

For Appellant: Sh. Nageswar Rao, Adv. &For Respondent: Sh. G.K.Dhall, CIT, DR
Section 143Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 271BSection 44B

…on vessel of the contractor itself constitutes a fixed place of assessee’s business in India. We draw our support from decision of Hon’ble Supreme Court in case of Formula One world Championship Ltd vs CIT (international taxation)-3, Delhi reported in (2017) 18 Taxmann.com 347. 6.9. On perusal of draft assessment order, as well as DRP order, we have observed certain discrepancies. For instance for assessment year 2009-10 Ld.AO held that assessee has a PE in India in the form of equipment. However DRP proceeded by observing that Ld.AO treated income from grouting services as fees for technical services. In our op…

Ulo Systems Llc, Gurgaon vs. DCIT, Dehradun

In the result appeals filed by assessee stands partly allowed as indicated above

ITA 653/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Mar 2019AY 2011-12

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2008-09 Ay: 2009-10 Ay: 2010-11 Ay: 2011-12 Ay: 2012-13 M/S Ulo Systems Llc Dcit, C/O S.R.Batliboi & Co., International Taxation Golf View Corporate Tower B Vs. Dehradun Near Dlf Golf Course Sector 42 Gurgaon 122 002

For Appellant: Sh. Nageswar Rao, Adv. &For Respondent: Sh. G.K.Dhall, CIT, DR
Section 143Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 271BSection 44B

…on vessel of the contractor itself constitutes a fixed place of assessee’s business in India. We draw our support from decision of Hon’ble Supreme Court in case of Formula One world Championship Ltd vs CIT (international taxation)-3, Delhi reported in (2017) 18 Taxmann.com 347. 6.9. On perusal of draft assessment order, as well as DRP order, we have observed certain discrepancies. For instance for assessment year 2009-10 Ld.AO held that assessee has a PE in India in the form of equipment. However DRP proceeded by observing that Ld.AO treated income from grouting services as fees for technical services. In our op…

Ulo Systems Llc, Gurgaon vs. ADIT, Dehradun

In the result appeals filed by assessee stands partly allowed as indicated above

ITA 6018/DEL/2013[2010-11]Status: DisposedITAT Delhi29 Mar 2019AY 2010-11

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2008-09 Ay: 2009-10 Ay: 2010-11 Ay: 2011-12 Ay: 2012-13 M/S Ulo Systems Llc Dcit, C/O S.R.Batliboi & Co., International Taxation Golf View Corporate Tower B Vs. Dehradun Near Dlf Golf Course Sector 42 Gurgaon 122 002

For Appellant: Sh. Nageswar Rao, Adv. &For Respondent: Sh. G.K.Dhall, CIT, DR
Section 143Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 271BSection 44B

…on vessel of the contractor itself constitutes a fixed place of assessee’s business in India. We draw our support from decision of Hon’ble Supreme Court in case of Formula One world Championship Ltd vs CIT (international taxation)-3, Delhi reported in (2017) 18 Taxmann.com 347. 6.9. On perusal of draft assessment order, as well as DRP order, we have observed certain discrepancies. For instance for assessment year 2009-10 Ld.AO held that assessee has a PE in India in the form of equipment. However DRP proceeded by observing that Ld.AO treated income from grouting services as fees for technical services. In our op…

Ulo Systems Llc, Gurgaon vs. ADIT Intl. Taxation, Dehradun

In the result appeals filed by assessee stands partly allowed as indicated above

ITA 4849/DEL/2012[2009-10]Status: DisposedITAT Delhi29 Mar 2019AY 2009-10

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2008-09 Ay: 2009-10 Ay: 2010-11 Ay: 2011-12 Ay: 2012-13 M/S Ulo Systems Llc Dcit, C/O S.R.Batliboi & Co., International Taxation Golf View Corporate Tower B Vs. Dehradun Near Dlf Golf Course Sector 42 Gurgaon 122 002

For Appellant: Sh. Nageswar Rao, Adv. &For Respondent: Sh. G.K.Dhall, CIT, DR
Section 143Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 271BSection 44B

…on vessel of the contractor itself constitutes a fixed place of assessee’s business in India. We draw our support from decision of Hon’ble Supreme Court in case of Formula One world Championship Ltd vs CIT (international taxation)-3, Delhi reported in (2017) 18 Taxmann.com 347. 6.9. On perusal of draft assessment order, as well as DRP order, we have observed certain discrepancies. For instance for assessment year 2009-10 Ld.AO held that assessee has a PE in India in the form of equipment. However DRP proceeded by observing that Ld.AO treated income from grouting services as fees for technical services. In our op…

Ulo Systems Llc., Gurgaon vs. ADIT, Dehradun

In the result appeals filed by assessee stands partly allowed as indicated above

ITA 5279/DEL/2011[2008-09]Status: DisposedITAT Delhi29 Mar 2019AY 2008-09

Bench: Smt. Beena A Pillai & Shri Prashant Maharishiay: 2008-09 Ay: 2009-10 Ay: 2010-11 Ay: 2011-12 Ay: 2012-13 M/S Ulo Systems Llc Dcit, C/O S.R.Batliboi & Co., International Taxation Golf View Corporate Tower B Vs. Dehradun Near Dlf Golf Course Sector 42 Gurgaon 122 002

For Appellant: Sh. Nageswar Rao, Adv. &For Respondent: Sh. G.K.Dhall, CIT, DR
Section 143Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 271BSection 44B

…on vessel of the contractor itself constitutes a fixed place of assessee’s business in India. We draw our support from decision of Hon’ble Supreme Court in case of Formula One world Championship Ltd vs CIT (international taxation)-3, Delhi reported in (2017) 18 Taxmann.com 347. 6.9. On perusal of draft assessment order, as well as DRP order, we have observed certain discrepancies. For instance for assessment year 2009-10 Ld.AO held that assessee has a PE in India in the form of equipment. However DRP proceeded by observing that Ld.AO treated income from grouting services as fees for technical services. In our op…