Dy. CIT v. Roxon OY

103 TTJ 891Income Tax Appellate Tribunal2006#5175 most cited

What is Dy. CIT v. Roxon OY authority for?

The principles for computing profits of an installation permanent establishment (PE) do not apply to the computation of profits of a dependent agency PE.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2023.

Also referred to as

Dy. CIT v. Roxon OY · installation PE · dependent agency PE · permanent establishment · computation of profits · taxability

Issues it is cited on

installation peuse of equipmentsection 44ddependent agent peagency pefunctional analysisservice peinterest on refundcopyrighted articlefar analysissection 115asection 234d

Judgments citing Dy. CIT v. Roxon OY

DDIT (IT) 2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4550/MUM/2013[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

ADIT (IT)-2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4575/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. ADIT (IT) RG 2(1), MUMBAI

Appeals are disposed off

ITA 3617/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. ADIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 5182/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

ADIT (IT) RG 2, MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 5155/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. DCIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 1287/MUM/2009[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1979/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1978/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. THE DDIT (IT)-2(1), MUMBAI

Appeals are disposed off

ITA 1709/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD,MUMBAI vs. THE DDIT (IT)-2(1), MUMBAI

Appeals are disposed off

ITA 1708/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. DDIT (I.T) - 2(1), MUMBAI

Appeals are disposed off

ITA 3422/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

ADIT (IT)-2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 3366/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

DDIT (INTERNATIONAL I. T) 2(1), MUMBAI vs. M/S. REUTERS ON LINE S.A, MUMBAI

Appeals are disposed off

ITA 5379/MUM/2005[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

THE DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 8464/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

THE DDIT (I.T) 2(1) vs. M/S. REUTERS LTD.,

Appeals are disposed off

ITA 8463/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. THE DY DIT (I.T) 2(1), MUMBAI

Appeals are disposed off

ITA 8348/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 5228/MUM/2004[2000-2001]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-2001

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

REFINITIV LTD.,MUMBAI vs. DDIT (I.TAXATION) RANGE 2, MUMBAI

Appeals are disposed off

ITA 5092/MUM/2004[2000-01]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-01

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

In the result, both the appeals filed by the Assessing Officer are dismissed, and both the appeals filed by the assessee are allowed in the limited terms indicated above

ITA 5025/MUM/2004[1999-2000]Status: DisposedITAT Mumbai05 Jul 2022AY 1999-2000
Section 143(3)

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

In the result, both the appeals filed by the Assessing Officer are dismissed, and both the appeals filed by the assessee are allowed in the limited terms indicated above

ITA 5024/MUM/2004[1998-1999]Status: DisposedITAT Mumbai05 Jul 2022AY 1998-1999
Section 143(3)

…fallacious assumption on the facts of the present case, that dependent agent and dependent agent permanent establishment are one and the same thing. 17. Learned counsel has then relied upon the order of this Tribunal in the case of Dy. CIT v. Roxon OY [2006] 103 TTJ 891 (Mum.) which was authored by one of us. This decision, however, did not deal with the peculiarities of a dependent agent permanent establishment. This decision dealt with the taxability of the installation PE, and, the principles dealing with computation of profits of installation PE, in our considered view, do not have any bearing on the computa…

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Dy. CIT v. Roxon OY (103 TTJ 891) — Cited in 22 Judgments | BharatTax