CIT v. P.V.A.L.Kulandagan

276 ITR 654Supreme Court of India#20265 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 362,824 Indian tax judgments — from 2018 to 2018.

Judgments citing CIT v. P.V.A.L.Kulandagan

Anz Operations and Technology Private Limited, Bangalore vs. DDIT, Bangalore

ITA 1508/BANG/2012[2008-09]Status: DisposedITAT Bangalore23 Mar 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri Kaushik Mukherjee, CAFor Respondent: Dr. P.V.Pradeep Kumar, Addl.CIT
Section 201(1)Section 9

…rence is required to the provisions of the Copyright Act or to any other source. In view of this, it is not necessary even to refer to the OECD model and commentaries etc. as per law explained by the Hon'ble Apex Court in the case of CIT v. P.V.A.L.Kulandagan 276 ITR 654 (SC). Accordingly, the reliance placed by the appellant on OECD commentaries and the US IRS Regulations is of no help to its case. It may be noted that the revised OECD commentary on software payment has not been accepted even by some of the OECD member countries and that the said commentary in any case cannot have precedence over the unambiguous…

Jubilant Biosys Limited, Noida vs. ITO, Bangalore

ITA 611/BANG/2010[2008-09]Status: DisposedITAT Bangalore23 Mar 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri Kaushik Mukherjee, CAFor Respondent: Dr. P.V.Pradeep Kumar, Addl.CIT
Section 201(1)Section 9

…rence is required to the provisions of the Copyright Act or to any other source. In view of this, it is not necessary even to refer to the OECD model and commentaries etc. as per law explained by the Hon'ble Apex Court in the case of CIT v. P.V.A.L.Kulandagan 276 ITR 654 (SC). Accordingly, the reliance placed by the appellant on OECD commentaries and the US IRS Regulations is of no help to its case. It may be noted that the revised OECD commentary on software payment has not been accepted even by some of the OECD member countries and that the said commentary in any case cannot have precedence over the unambiguous…

Jubilant Biosys Limited, Noida vs. ITO, Bangalore

ITA 610/BANG/2010[2007-08]Status: DisposedITAT Bangalore23 Mar 2018AY 2007-08

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri Kaushik Mukherjee, CAFor Respondent: Dr. P.V.Pradeep Kumar, Addl.CIT
Section 201(1)Section 9

…rence is required to the provisions of the Copyright Act or to any other source. In view of this, it is not necessary even to refer to the OECD model and commentaries etc. as per law explained by the Hon'ble Apex Court in the case of CIT v. P.V.A.L.Kulandagan 276 ITR 654 (SC). Accordingly, the reliance placed by the appellant on OECD commentaries and the US IRS Regulations is of no help to its case. It may be noted that the revised OECD commentary on software payment has not been accepted even by some of the OECD member countries and that the said commentary in any case cannot have precedence over the unambiguous…

Anz Operations and Technology Private Limited, Bangalore vs. DDIT, Bangalore

ITA 193/BANG/2010[2008-09]Status: DisposedITAT Bangalore23 Mar 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri Kaushik Mukherjee, CAFor Respondent: Dr. P.V.Pradeep Kumar, Addl.CIT
Section 201(1)Section 9

…rence is required to the provisions of the Copyright Act or to any other source. In view of this, it is not necessary even to refer to the OECD model and commentaries etc. as per law explained by the Hon'ble Apex Court in the case of CIT v. P.V.A.L.Kulandagan 276 ITR 654 (SC). Accordingly, the reliance placed by the appellant on OECD commentaries and the US IRS Regulations is of no help to its case. It may be noted that the revised OECD commentary on software payment has not been accepted even by some of the OECD member countries and that the said commentary in any case cannot have precedence over the unambiguous…

CIT v. P.V.A.L.Kulandagan (276 ITR 654) — Cited in 4 Judgments | BharatTax