CIT v. CGI Information Systems & Management Consultants (P.) Ltd.

48 Taxmann.com 264High Court2014#5575 most cited

What is CIT v. CGI Information Systems & Management Consultants (P.) Ltd. authority for?

Payments made by an assessee for intra-net facilities provided by a non-resident company constitute royalty under Section 9(1)(vi) of the Income Tax Act, making them liable to tax.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2022.

Also referred to as

CIT v. CGI Information Systems & Management Consultants · Section 9(1)(vi) · Section 40(a) · royalty · copyrighted article · computer software · intra-net facilities · non-resident · liable to tax · taxability of royalty

Also reported as

275 CTR 72

Issues it is cited on

copyrighted articlesection 9(1)(vi)computer softwaresection 9(1)liable to taxsection 40(a)section 234bsection 234asection 19double taxationdraft assessment ordersection 40

Judgments citing CIT v. CGI Information Systems & Management Consultants (P.) Ltd.

Galatea Ltd, Mumbai vs. DCIT (It) RG 2(3)(2), Mumbai

In the result, the assessee’s appeal for A

ITA 5434/MUM/2015[2012-13]Status: DisposedITAT Mumbai29 Jun 2016AY 2012-13

Bench: Shri Jason P. Boaz & Shri Saktijit Daym/S. Galatea Ltd. Dcit (International Taxation) P.O. 1156, Industrial Vs. Range 2(3)(2) Area, Dalton, Israel Mumbai Pan - Aadcg8396D Appellant Respondent

For Appellant: Shri Bomi Daruwala &For Respondent: Shri Jasbir Chouhan
Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 9(1)(vi)Section 90(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL "L" Bench, Mumbai Before Shri Jason P. Boaz, Accountant Member and Shri Saktijit Day, Judicial Member M/s. Galatea Ltd. DCIT (International Taxation) P.O. 1156, Industrial Vs. Range 2(3)(2) Area, Dalton, Israel Mumbai PAN - AADCG8396D Appellant Respondent Appellant by: Shri Bomi Daruwala & Ms. Priyanka Jain Respondent by: Shri Jasbir Chouhan Date of Hearing: 21.06.2016 Date of Pronouncement: 29.06.2016 O R D E R Per Jason P. Boaz, A.M. This appeal by the assessee is directed against the final order of assessment for A.Y. 2012-13 passed under section 143(3) r.w.s. 144C(13…