Reuters Transaction Services Pvt Ltd. v. DDIT

151 ITD 510Income Tax Appellate Tribunal2014#5204 most cited

What is Reuters Transaction Services Pvt Ltd. v. DDIT authority for?

A prior ruling is not applicable if the facts differ, particularly concerning the provision of equipment and systems. The core reasoning of a previous decision can be distinguished if the factual matrix, such as who bears the cost of necessary equipment, is different.

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

Reuters Transaction Services Pvt Ltd v DDIT · 151 ITD 510 · fees for technical services · Indo-UK tax treaty · provision of system · application programming interface · use of equipment · Indian entity expense

Issues it is cited on

installation pe use of equipment section 44d dependent agent pe agency pe functional analysis service pe interest on refund copyrighted article far analysis section 115a section 234d

Judgments citing Reuters Transaction Services Pvt Ltd. v. DDIT

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

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

…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

ITA 5025/MUM/2004[1999-2000]Status: DisposedITAT Mumbai05 Jul 2022AY 1999-2000

…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

ITA 5024/MUM/2004[1998-1999]Status: DisposedITAT Mumbai05 Jul 2022AY 1998-1999

…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…

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Reuters Transaction Services Pvt Ltd. v. DDIT (151 ITD 510) — Cited in 22 Judgments | BharatTax