DCIT v. Stock Engineering and Contractors BV

32 SOT 249Income Tax Appellate Tribunal#12616 most cited
8

judgments rely on this decision, according to BharatTax’s citation analysis of 350,364 Indian tax judgments — from 2016 to 2016.

Judgments citing DCIT v. Stock Engineering and Contractors BV

Mc Dermott Eastern Hemisphere Td ( Formelry Known As J. Ray Mc Dermott Eastern Hemisphere Ltd), Mumbai vs. DDIT (It) 3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 7855/MUM/2011[2008-09]Status: DisposedITAT Mumbai06 May 2016AY 2008-09

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J Ray Mcdermott Eastern Hemisphere Ltd, Mumbai vs. DDIT (It) 3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 8720/MUM/2010[2004-05]Status: DisposedITAT Mumbai06 May 2016AY 2004-05

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J Ray Mcdermott Eastrn Hemisphere Ltd, Mumbai vs. DDIT (It) 3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 8718/MUM/2010[2007-08]Status: DisposedITAT Mumbai06 May 2016AY 2007-08

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J Ray Mcdermott Eastrn Hemisphere Ltd, Mumbai vs. DDIT (It), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 8717/MUM/2010[2005-06]Status: DisposedITAT Mumbai06 May 2016AY 2005-06

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J. Ray Mc Dermott Eastern Hemisphere Ltd, Mumbai vs. ADIT (It)-3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 2227/MUM/2009[2002-2003]Status: DisposedITAT Mumbai06 May 2016AY 2002-2003

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J. Ray Mc Dermott Eastern Hemisphere Ltd, Mumbai vs. ADIT (It)-3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 2226/MUM/2009[2000-2001]Status: DisposedITAT Mumbai06 May 2016AY 2000-2001

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

M/S. J. Ray Mc Dermott Eastern Hemisphere Ltd, Mumbai vs. The ACIT It 3(1), Mumbai

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 2309/MUM/2006[2002-2003]Status: DisposedITAT Mumbai06 May 2016AY 2002-2003

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

J.Ray Mc Dermott Eastern Hemisphere Ltd vs. The Jdit (It) 4

In the result, appeals filed by the assessee and revenue are partly allowed for statistical purposes

ITA 5302/MUM/2004[2000-01]Status: DisposedITAT Mumbai06 May 2016AY 2000-01

Bench: Shri C.N. Prasad & Shri Ashwani Tanejaassessment Year: 1998-99 Adit (It) 1(2), M/S. J. Ray Mc Dermott Eastern Aayakar Bhavan, Hemisphere Ltd., बनाम/ M.K. Road, C/O. Price Waterhouse & Co. Cas Vs. Mumbai-400020 Trade World, ‘C’ Wing, 8Th Floor, Kamla Mills Compound, Lower Parel, Senapati Bapat Marg Mumbai- 400013 (Assessee) (Revenue) P.A. No. Aabcm1087F

…article, and therefore, the case of the assessee can not fall under article 5(2)(c) which determines the PE on the basis of existence of office. In support of his arguments, Ld. Counsel relied upon the judgment of DCIT v. Stock Engineering and Contractors BV 32 SOT 249 (ITAT Mumbai) wherein it was held that if two clauses of the Article are applicable upon the assessee in two factual situations, then the one which is more beneficial to the assessee would be applicable. It was further submitted by him that in assessee’s own case, Hon’ble Tribunal in assessment A.Y. 1997-98 inter-alia held that even if there exist…

DCIT v. Stock Engineering and Contractors BV (32 SOT 249) — Cited in 8 Judgments | BharatTax