CIT v. Ad2Pro Media Solutions Pvt. Ltd.

455 ITR 648High Court2023#25043 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 348,356 Indian tax judgments — from 2024 to 2025.

Sections most often in play

Section 147Section 148Section 9(1)(vii)Section 144CSection 195Section 234ASection 234BSection 115A

Issues it is cited on

service pesection 9(1)(vi)section 9(1)(vii)fees for technical servicespermanent establishmentsection 195section 9(1)associated enterprisedispute resolution panelnon-residentreason to believereopening of assessment

Judgments citing CIT v. Ad2Pro Media Solutions Pvt. Ltd.

Same Deutz Fahr Italia Spa, Italy vs. Assistant Commissioner, Chennai

In the result the appeal of the assessee is allowed

ITA 937/CHNY/2024[AY 2016-17]Status: DisposedITAT Chennai30 Jan 2025

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 147Section 148Section 250o

…ce and repairs payments were for the purpose of earning abroad. In these circumstances, the ITAT's factual findings cannot be faulted. The question of law is answered in favour of the assessee and against the revenue." :-20-: ITA. No:937/Chny/2024 2. [2023] 455 ITR 648 (Karnataka) CIT Vs.Ad2pro Media solutions Pvt Ltd. "18. After adverting to the following passage, the Delhi High Court has recorded that in Lufthansa Cargo India's case (supra) operations were not in India and expenses towards maintenance and repairs payments were made for the purpose of earning outside India. "The exception carved out in the lat…

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 833/BANG/2024[2014-15]Status: DisposedITAT Bangalore10 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

…see Steer America Inc, does not render services resulting in provision 'Fee for Technical Services' (FTS) or Make available Technical Knowledge to Steer India. 9.16 Further, Hon’ble Karnataka High Court in the case of CIT Vs. Ad2Pro Media Solutions Pvt. Ltd. 455 ITR 648 (Karn) held as under: “The assessee has made payments to the US Company which does not have any permanent establishment in India. [Para 8] The revenue's case is payments made to the US Company for marketing services take the character of FTS and chargeable to tax in India. [Para 9] Thus, according to the revenue the royalties and fees for includ…

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 832/BANG/2024[2013-14]Status: DisposedITAT Bangalore10 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

…see Steer America Inc, does not render services resulting in provision 'Fee for Technical Services' (FTS) or Make available Technical Knowledge to Steer India. 9.16 Further, Hon’ble Karnataka High Court in the case of CIT Vs. Ad2Pro Media Solutions Pvt. Ltd. 455 ITR 648 (Karn) held as under: “The assessee has made payments to the US Company which does not have any permanent establishment in India. [Para 8] The revenue's case is payments made to the US Company for marketing services take the character of FTS and chargeable to tax in India. [Para 9] Thus, according to the revenue the royalties and fees for includ…

CIT v. Ad2Pro Media Solutions Pvt. Ltd. (455 ITR 648) — Cited in 3 Judgments | BharatTax