ROCKWELL COLLINS, INC.,UNITED STATES OF AMERICA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE 3(1)(1), DELHI, DELHI
In the result, the appeal of the assessee in ITA No
ITA 2410/DEL/2023[2020-21]Status: DisposedITAT Delhi14 Nov 2024AY 2020-21
Bench: Shri M. Balaganesh & Shri Anubhav Sharmarockwell Collins Vs. Dcit, Southeast Asia Pte Ltd, Circle-3(1)(1), 18, Loyang Lane, Delhi 508918, Singapore, Singapore (Appellant) (Respondent) Pan:Aajcr7985R Rockwell Collins Inc, Vs. Dcit, 400, Collins Rd Ne, Circle-3(1)(1), Cedar Rapids, Ia 52498, Delhi United States Of America, Usa,52498 (Appellant) (Respondent) Pan:Aajcr7883E
For Appellant: Shri Rajan Vora, CAFor Respondent: Ms. C. Chandra Kanta, CIT DR
Section 9(1)(vii)
…per section 194C of the Act which fact is also clarified by CBDT in its Circular No. 715 dated 08.08.1995 vide Question No. 29. Further, the assessee also submitted that co-ordinate bench of Delhi Tribunal in the case of Parasrampuria Synthetics Ltd reported 20 SOT 248 (Del Trib) held that use of services of technically qualified persons to render the services did not bring the amount paid as “fee for technical services” within the meaning of Explanation 2 to Section 9(1)(vii) of the Act. Similar decision was rendered by Delhi Tribunal in the case of Spicejet Ltd reported in 145 taxmann.com 622 (Del Trib). The a…
