Reuters Transaction Services Pvt Ltd. v. DDIT

DDIT (It) 2(1), Mumbai vs. Reuters Ltd, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

ADIT (It)-2(1), Mumbai vs. Reuters Ltd, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. ADIT (It) RG 2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. ADIT (It) 2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

ADIT (It) RG 2, Mumbai vs. Reuters Ltd, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. DCIT (It) 2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

The DDIT(It)-2(1), Mumbai vs. M/S. Reuters Ltd, Uk, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

The DDIT(It)-2(1), Mumbai vs. M/S. Reuters Ltd, Uk, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. The DDIT (It)-2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd, Mumbai vs. The DDIT (It)-2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. DDIT (I.T) - 2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

ADIT (It)-2(1), Mumbai vs. M/S. Reuters Ltd., Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

DDIT (International I. T) 2(1), Mumbai vs. M/S. Reuters on Line S.A, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

The DDIT (I.T) 2(1), Mumbai vs. M/S. Reuters Ltd., Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

The DDIT (I.T) 2(1) vs. M/S. Reuters Ltd

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. The Dy DIT (I.T) 2(1), Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

DDIT (I.T) 2(1), Mumbai vs. M/S. Reuters Ltd., Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

Refinitiv Ltd., Mumbai vs. DDIT (I.Taxation) Range 2, Mumbai

Appeals are disposed off

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative"s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative‟s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…

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

…as the fees for technical services under the Indo- UK tax treaty. 7. We have also taken note of the learned Departmental Representative‟s vehement reliance on the order of a coordinate bench in the case of Reuters Transaction Services Pvt Ltd Vs DDIT [(2014) 151 ITD 510 (Mum)], but that was a case in which the assessee had provided its clients its system and application programming interface, including interactive features and use of equipment. In the present case, however, as the agreement specifically provides in Article 8, at page 8 of the agreement, „all equipment necessary for reception and distribution of…