How many judgments cite CLSA Ltd. v. ITO(IT)?

21 judgments on BharatTax cite CLSA Ltd. v. ITO(IT) (305 ITR 208), spanning 2016 to 2024.

CLSA Ltd. v. ITO(IT)

Q: Which sections of the Income Tax Act does CLSA Ltd. v. ITO(IT) come up under?

It is most often cited in judgments turning on Section 1961, Section 139(1) of the Income Tax Act, Section 139(9) of the Income Tax Act, Section 143(3) of the Income Tax Act, Section 144C of the Income Tax Act, Section 144C(1) of the Income Tax Act.

305 ITR 208Reported decision2008#5500 most cited

What is CLSA Ltd. v. ITO(IT) authority for?

Payments received for referring international clients to another entity do not constitute 'fees for technical services' if they do not involve rendering technical, managerial, or consultancy services. Such fees may be construed as commission income.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,383 Indian tax judgments — from 2016 to 2024.

Also referred to as

CLSA Ltd. v. ITO · section 9(1)(vii) · fees for technical services · referral fee · commission income · DTAA · Article 12 · Explanation 2 to section 9(1)(vii) · international clients

Sections most often in play

Section 1961 Section 139(1) of the Income Tax Act Section 139(9) of the Income Tax Act Section 143(3) of the Income Tax Act Section 144C of the Income Tax Act Section 144C(1) of the Income Tax Act Section 195 of the Income Tax Act Section 270A of the Income Tax Act

Issues it is cited on

section 40(a)(1)section 248 section 9(1)(vii)(b)section 195(1)section 195(2)fees for included services interest free advances business connection section 9(1)(vi)section 9(1)(vii)section 40(a)(i)enduring benefit

Judgments citing CLSA Ltd. v. ITO(IT)

DCIT 17(1), Mumbai vs. Shm Shipcare, Mumbai

ITA 1047/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Feb 2016AY 2008-09

For Appellant: NoneFor Respondent: Shri Pankaj Kumar

Section 143(3)Section 254(1)Section 40Section 9(1)(i)Section 9(1)(vi)

…mercial/scientific knowledge, experience or skill., that they were also not rendering any services in connection with the activities referred in the sub clauses of Explanation 2 to section 9(1)(vi).He referred to the case of Cushman and Wakefield (S) Pte.Ltd.(305 ITR 208) and Sheraton International Inc.(313ITR267), that the assessee was not obliged to deduct TDS on service charges.Finally,he deleted the addition made toward service charges.With regard to training fee,the FAA held that personnel of the assessee were trained by the suppliers of the equipments,that the staff members were sent abroad for training, th…