Lucent Technologies International Inc. v. DCIT, Non

28 SOT 98Income Tax Appellate Tribunal#24183 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2018 to 2018.

Judgments citing Lucent Technologies International Inc. v. DCIT, Non

DCIT (It) 3(1)(2), Mumbai vs. Lucent Technologies Crl Llc, Mumbai

In the result, the appeal filed by the assessee is allowed and the appeal filed by the

ITA 678/MUM/2016[2012-13]Status: DisposedITAT Mumbai13 Aug 2018AY 2012-13

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Respondent: Shri Madhur Agarwal
Section 144Section 144C(5)Section 234BSection 271

…ssee was not rendering any service in India nor LTHPL is authorized to deal with outsiders on behalf of assessee Lucent. Further, it was submitted that the co-ordinate Bench in the case of Lucent Technologies International Inc. vs. DCIT, Non- resident Circle (28 SOT 98) considered the facts in the case to hold that there is a service PE in that case. It was submitted that mere existence of a PE to a group company does not lead to a finding that the assessee also as a PE in India. It was further submitted that AO’s reliance on a document i.e., subsequent restructured agreement for payment by the group companies do…

Lucent Technologies Grl Llc, Mumbai vs. Jdit (It) RG 4, Mumbai

In the result, these appeals by the assessee stands allowed

ITA 7704/MUM/2012[2009-10]Status: DisposedITAT Mumbai13 Aug 2018AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Samuel Darse
Section 115Section 115ASection 144C(1)Section 144C(5)Section 44D

…ssee was not rendering any service in India nor LTHPL is authorized to deal with outsiders on behalf of assessee Lucent. Further, it was submitted that the co-ordinate Bench in the case of Lucent Technologies International Inc. vs. DCIT, Non- resident Circle (28 SOT 98) considered the facts in the case to hold that there is a service PE in that case. It was submitted that mere existence of a PE to a group company does not lead to a finding that the assessee also as a PE in India. It was further submitted that AO’s reliance on a document i.e., subsequent restructured agreement for payment by the group companies do…

Lucent Technolgies Grl Llc, Mumbai vs. DDIT (It) 4(1), Mumbai

In the result, the appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 1934/MUM/2014[2010-11]Status: DisposedITAT Mumbai16 Jul 2018AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am

For Appellant: Shri PJ PardiwalaFor Respondent: Shri Samuel Darse, DR
Section 143(3)Section 144C(1)Section 9(1)(vi)

…ssee was not rendering any service in India nor LTHPL is authorized to deal with outsiders on behalf of assessee Lucent. Further, it was submitted that the co-ordinate Bench in the case of Lucent Technologies International Inc. vs. DCIT, Non- resident Circle (28 SOT 98) considered the facts in the case to hold that there is a service PE in that case. It was submitted that mere existence of a PE to a group company does not lead to a finding that the assessee also as a PE in India. It was further submitted that AO’s reliance on a document i.e., subsequent restructured agreement for payment by the group companies do…

Lucent Technologies International Inc. v. DCIT, Non (28 SOT 98) — Cited in 3 Judgments | BharatTax