CIT v. Bio-Rad Lab (Singapore) Pte Ltd.

155 Taxmann 646High Court#12216 most cited
8

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

Sections most often in play

Section 10AASection 195Section 234BSection 234CSection 271(1)(c)Section 37(1)Section 80IA(8)Section 90

Issues it is cited on

section 80ia(8)section 9(1)(vii)(b)section 195(2)fees for included servicessection 90(2)business connectionsection 9(1)(vii)section 10aainterest u/s 234bfees for technical servicessection 10asection 80ia

Judgments citing CIT v. Bio-Rad Lab (Singapore) Pte Ltd.

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7366/DEL/2019[2016-17]Status: DisposedITAT Delhi29 Nov 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1008/DEL/2019[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 8081/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Nov 2024AY 2013-14

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4716/DEL/2018[2015-16]Status: DisposedITAT Delhi29 Nov 2024AY 2015-16

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2893/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6332/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

M/S. Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1009/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Nov 2024AY 2011-12

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…harges on yearly basis to ESG International which indicates no technology has been transferredand hence the 'make available’ conditions are not complied with. Therefore, the decision of the Hon'ble Delhi High Court in CIT vs. Bio-Rad Lab (Singapore) Pte Ltd 155 Taxmann 646 (Delhi) (2024) squarely applies that the continued provisioning and rendering of services over a substantial period of time would clearly detract from an assumption that technical or consultancy services had been ‘made available’. On this account also the payment made to ESGI do not fall under the description of FTS and accordingly we hol…

Nord Anglia Education Limited, United Kingdom vs. DCIT Intl. Taxation Circle 2(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2385/DEL/2023[2020-21]Status: DisposedITAT Delhi07 Aug 2024AY 2020-21

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Kanchan Kaushal, AdvFor Respondent: Sh. Vijay B. Vasanta, CIT-DR
Section 143(3)Section 144CSection 270A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI Before Sh. Saktijit Dey, Vice President Dr. B. R. R. Kumar, Accountant Member ITA No. 2385/Del/2023 : Asstt. Year : 2020-21 Nord Anglia Education Ltd., Vs. DCIT, 4th Floor, Nova South, 160, Victoria International Taxation, Street, London, United Kingdom-SW1E5JB Circle-2(2)(2), New Delhi-110002 (APPELLANT) (RESPONDENT) PAN No. AAGCN2898G Assessee by : Sh. Kanchan Kaushal, Adv. Revenue by : Sh. Vijay B. Vasanta, CIT-DR Date of Hearing: 08.05.2024 Date of Pronouncement: 07.08.2024 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has…

CIT v. Bio-Rad Lab (Singapore) Pte Ltd. (155 Taxmann 646) — Cited in 8 Judgments | BharatTax