CIT v. Goodyear Tyre & Rubber Co.

184 ITR 369High Court1989#15153 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2016 to 2016.

Judgments citing CIT v. Goodyear Tyre & Rubber Co.

ITO (TDS), New Delhi vs. Bharti Airtel Ltd., Gurgaon

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4077/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

ITO (TDS), New Delhi vs. Bharti Airtel Ltd., Gurgaon

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 4076/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3596/DEL/2012[2011-12 (F.Y. 2010-11)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3595/DEL/2012[2010-11 (F.Y. 2009-10)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3594/DEL/2012[2009-10 (F.Y. 2008-09)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

Bharti Airtel Ltd., Gurgaon vs. ITO (TDS), New Delhi

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

ITA 3593/DEL/2012[2008-09 (F.Y. 2007-08)]Status: DisposedITAT Delhi17 Mar 2016

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

For Appellant: Sh. S.K. Tulsiyan, Adv., ShFor Respondent: Sh. Anuj Arora, CIT(DR)
Section 194JSection 201Section 201(1)Section 9Section 9(1)(vii)

…o part of the income as relatable to the sale of equipment by the assessee can be said to have deemed to accrue or arise to the assessee in India within the meaning of s. 9." 77. The Hon’ble High Court in the case of CIT vs. Goodyear Tyre & Rubber Co. (1989) 184 ITR 369 (Del.) held that even though the non-resident had a business connection in India, if no operations were carried out in India, the income cannot be subject to tax in India. Hence, the payment cannot be brought within the ambit of Section 9(1) r.w.s. 5(2) of the Act. 78. Even under the DTAA, the payments being in the nature of business income of t…

CIT v. Goodyear Tyre & Rubber Co. (184 ITR 369) — Cited in 6 Judgments | BharatTax