S.M. Ram Lal & Co. v. Secretary to Government of Punjab

5 SCC 574Reported decision1998#5383 most cited
22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Sections most often in play

Section 12Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 3(2)Section 5

Issues it is cited on

section 206asection 206aause of equipmentsection 9(l)(vii)section 9(l)section 9(l)(vi)section 44bbsection 195(2)section 44bsection 9(1)(vi)withholding taxsection 90(2)

Judgments citing S.M. Ram Lal & Co. v. Secretary to Government of Punjab

RELIANCE JIO INFOCOMM USA INC.,TEXAS vs. DCIT (IT) 4 (1) (1), MUMBAI

In the result appeal filed by the assessee stands allowed

ITA 2991/MUM/2023[2020-21]Status: DisposedITAT Mumbai17 Apr 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Bijayananda Pruseth ()

Section 143(2)Section 143(3)Section 144C(5)Section 153Section 9(1)(vi)Section 9(1)(vii)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 111/IND/2015[2013-14 (Quarter 4)]Status: DisposedITAT Indore01 Aug 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the Page 23 of 55 [[[ ITA No. 109 to 111/Ind/2023 – AYs 2012-13, 2013-14 & 2013-14 M/s Idea Cellular Ltd., Indore. New Shorter Oxford Dictionary, mor…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 110/IND/2015[2013-14 (for first three quarter)]Status: DisposedITAT Indore01 Aug 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the Page 23 of 55 [[[ ITA No. 109 to 111/Ind/2023 – AYs 2012-13, 2013-14 & 2013-14 M/s Idea Cellular Ltd., Indore. New Shorter Oxford Dictionary, mor…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 109/IND/2015[2012-13]Status: DisposedITAT Indore01 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 194Section 194HSection 194JSection 201(1)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the Page 23 of 55 [[[ ITA No. 109 to 111/Ind/2023 – AYs 2012-13, 2013-14 & 2013-14 M/s Idea Cellular Ltd., Indore. New Shorter Oxford Dictionary, mor…

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, BANGALORE

ITA 811/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubeyit(It)A No.811/Bang/2024 & Sp No.22/Bang/2024

Section 143(3)Section 144C(13)Section 147Section 201Section 9Section 9(1)(vi)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

GLOBE TELESERVICES LIMITED,HONG KONG vs. THE DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE-2(1), BANGALORE, BANGALORE

ITA 349/BANG/2024[2017-18]Status: DisposedITAT Bangalore24 Apr 2024AY 2017-18

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuit(It)A Nos. 348 & 349/Bang/2024

For Appellant: Shri Rohan Sogani, CA &For Respondent: Shri A. Sreenivasa Rao, CIT-DR
Section 147Section 191Section 201Section 9(1)(vi)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

GLOBE TELESERVICES LIMITED,HONG KONG vs. THE DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE-2(1), BANGALORE, BANGALORE

ITA 348/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Apr 2024AY 2014-15

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuit(It)A Nos. 348 & 349/Bang/2024

For Appellant: Shri Rohan Sogani, CA &For Respondent: Shri A. Sreenivasa Rao, CIT-DR
Section 147Section 191Section 201Section 9(1)(vi)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

ITA 265/IND/2018[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

…ut the particular meaning appropriate to the context Page 24 of 65 ITA No. 415/Ind/2014 & 265/Ind/2018 – AY 2010-11 M/s Vodafone Idea Ltd. (Formerly M/s Idea Cellular Ltd.) should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

ITA 415/IND/2014[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

…ut the particular meaning appropriate to the context Page 24 of 65 ITA No. 415/Ind/2014 & 265/Ind/2018 – AY 2010-11 M/s Vodafone Idea Ltd. (Formerly M/s Idea Cellular Ltd.) should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, JAPAN

ITA 102/BANG/2024[2015-16]Status: DisposedITAT Bangalore15 Apr 2024AY 2015-16

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahus.P. Nos. 7 To 9/Bang/2024 (In It(It)A Nos. 100 To 102/Bang/2024) & It(It)A Nos. 100 To 102/Bang/2024

For Appellant: Shri Arjit Prasad, Sr. AdvocateFor Respondent: Dr. Subash K R, CIT-DR
Section 143(3)Section 144C(1)Section 144C(3)Section 147Section 148Section 201

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, BANGALORE

ITA 101/BANG/2024[2014-15]Status: DisposedITAT Bangalore15 Apr 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahus.P. Nos. 7 To 9/Bang/2024 (In It(It)A Nos. 100 To 102/Bang/2024) & It(It)A Nos. 100 To 102/Bang/2024

For Appellant: Shri Arjit Prasad, Sr. AdvocateFor Respondent: Dr. Subash K R, CIT-DR
Section 143(3)Section 144C(1)Section 144C(3)Section 147Section 148Section 201

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, BANGALORE

ITA 100/BANG/2024[2013-14]Status: DisposedITAT Bangalore15 Apr 2024AY 2013-14

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahus.P. Nos. 7 To 9/Bang/2024 (In It(It)A Nos. 100 To 102/Bang/2024) & It(It)A Nos. 100 To 102/Bang/2024

For Appellant: Shri Arjit Prasad, Sr. AdvocateFor Respondent: Dr. Subash K R, CIT-DR
Section 143(3)Section 144C(1)Section 144C(3)Section 147Section 148Section 201

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2), INTERNATIONAL TAXATION, BENGALURU, BENGALURU vs. ORANGE (FORMERLY KNOWN AS FRANCE TELECOM)), FRANCE

In the result, the appeal filed by the revenue stands dismissed

ITA 711/BANG/2023[2011-12]Status: DisposedITAT Bangalore22 Dec 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A No. 711/Bang/2023 Assessment Year : 2011-12 M/S. Orange The Deputy (Formerly Known As Commissioner Of France Telecom), Income Tax, 78, Rue Olivaier De Circle – 2(2), Serres, International Paris, Taxation, Vs. France. Bengaluru. Pan: Aacco8859J Appellant Respondent Assessee By : None Revenue By : Shri D.S. Karthik, Jcit (Dr)

For Appellant: NoneFor Respondent: Shri D.S. Karthik, JCIT (DR)
Section 14Section 147Section 148Section 201Section 9

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; Page 16 of 27 IT(IT)A No. 711/Bang/2023 putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there…

M/S. TELECOM ITALIA SPARKLE SINGAPORE PTE. LIMITED,SINGAPORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION- CIRCLE 2(1), BANGALORE

In the result, all the three appeals filed by assessee stands partly allowed

ITA 580/BANG/2020[2010-11]Status: DisposedITAT Bangalore31 Aug 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 579 & 580/Bang/2020 Assessment Years : 2009-10 To 2010-11 M/S. Telecom Italia The Deputy Sparkle Singapore Pte. Commissioner Of Ltd., Income Tax, 23-01, Suntec Tower (International Four, Taxation), 6 Temasek Boulevard, Vs. Circle – 2(1), Singapore – 038986 Bangalore. Pan: Aagct6780P Appellant Respondent & It(It)A No. 1138/Bang/2022 Assessment Year : 2011-12 M/S. Ti Sparkle The Deputy Singapore Pte. Ltd., Commissioner Of 23-01, Suntec Tower Income Tax, Four, (International 6 Temasek Boulevard, Taxation), Singapore – 038986 Circle – 2(2), Vs. Pan: Aagct6780P Bangalore. Appellant Respondent

For Appellant: Shri Nitesh Joshi, CAFor Respondent: Shri Nischal .B, Addl. CIT (DR)
Section 148Section 195Section 201(1)Section 9(1)(vi)

…variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to Page 17 IT(IT)A Nos. 579 & 580/Bang/2020 & 1138/Bang/2022 the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

M/S. TELECOM ITALIA SPARKLE SINGAPORE PTE. LIMITED,SINGAPORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION- CIRCLE 2(1), BANGALORE

In the result, all the three appeals filed by assessee stands partly allowed

ITA 579/BANG/2020[2009-10]Status: DisposedITAT Bangalore31 Aug 2023AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 579 & 580/Bang/2020 Assessment Years : 2009-10 To 2010-11 M/S. Telecom Italia The Deputy Sparkle Singapore Pte. Commissioner Of Ltd., Income Tax, 23-01, Suntec Tower (International Four, Taxation), 6 Temasek Boulevard, Vs. Circle – 2(1), Singapore – 038986 Bangalore. Pan: Aagct6780P Appellant Respondent & It(It)A No. 1138/Bang/2022 Assessment Year : 2011-12 M/S. Ti Sparkle The Deputy Singapore Pte. Ltd., Commissioner Of 23-01, Suntec Tower Income Tax, Four, (International 6 Temasek Boulevard, Taxation), Singapore – 038986 Circle – 2(2), Vs. Pan: Aagct6780P Bangalore. Appellant Respondent

For Appellant: Shri Nitesh Joshi, CAFor Respondent: Shri Nischal .B, Addl. CIT (DR)
Section 148Section 195Section 201(1)Section 9(1)(vi)

…variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to Page 17 IT(IT)A Nos. 579 & 580/Bang/2020 & 1138/Bang/2022 the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

TELEFONICA DE ESPANA SA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-2(2), BANGALORE

In the result, all the three appeals filed by the assessee stands partly allowed as indicated hereinabove

ITA 180/BANG/2021[2011-12]Status: DisposedITAT Bangalore10 Aug 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 2657/Bang/2019, 180/Bang/2021 & 817/Bang/2022 Assessment Years : 2010-11 To 2012-13 M/S. Telefonica Depreciation Espana Sa, C/O. Bsr & Co.Llp, 3Rd Floor, Pebble The Acit(It)/Dcit(It), Beach, Circle – 2(2), Embassy Golf Links Bangalore. Business Park, Vs. Off Intermediate Ring Road, Bangalore – 560 071. Pan: Aahct0411G Appellant Respondent Assessee By : Shri Sharath Rao, Ca Revenue By : Shri D.K. Mishra, Cit Dr

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT DR
Section 147Section 148Section 201Section 234ASection 9(1)(vi)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

M/S. TELEFONICA DE ESPANA SA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), CIRCLE- 2(2), BANGALORE

In the result, all the three appeals filed by the assessee stands partly allowed as indicated hereinabove

ITA 2657/BANG/2019[2010-11]Status: DisposedITAT Bangalore10 Aug 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 2657/Bang/2019, 180/Bang/2021 & 817/Bang/2022 Assessment Years : 2010-11 To 2012-13 M/S. Telefonica Depreciation Espana Sa, C/O. Bsr & Co.Llp, 3Rd Floor, Pebble The Acit(It)/Dcit(It), Beach, Circle – 2(2), Embassy Golf Links Bangalore. Business Park, Vs. Off Intermediate Ring Road, Bangalore – 560 071. Pan: Aahct0411G Appellant Respondent Assessee By : Shri Sharath Rao, Ca Revenue By : Shri D.K. Mishra, Cit Dr

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT DR
Section 147Section 148Section 201Section 234ASection 9(1)(vi)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1345/BANG/2019[2017-18]Status: DisposedITAT Bangalore31 May 2022AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1344/BANG/2019[2016-17]Status: DisposedITAT Bangalore31 May 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

…meaning of the key word 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

AMADEUS GLOBAL TRAVEL DISTRIBUTION SA,SPAIN vs. ADIT, NEW DELHI

The appeal of the assessee is allowed with above direction

ITA 1494/DEL/2011[2006-07]Status: DisposedITAT Delhi18 Jul 2019AY 2006-07

Bench: Shri Kuldip Singh & Shri Prashant Maharishiamadeus Global Travel Vs. Adit, Distribution Sa Circle-1(1), (Now Known As Amadeus It International Taxation, Group Sa), New Delhi Salvador De Madariaga, E- 28027, Madrid, Spain Pan: Aafca9629P (Appellant) (Respondent)

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 80HSection 9

…meaning of the keyword 'use'. The expression 'use' has a variety of meanings and is often employed in a very wide sense, but the particular meaning appropriate to the context should be chosen. In S.M. Ram Lal & Co. v. Secretary to Government of Punjab [1998] 5 SCC 574, the Supreme Court noted that 'in its ordinary meaning', "the word 'use' as a noun, is the act of employing a thing; putting into action or service, employing for or applying to a given purpose". In the New Shorter Oxford Dictionary, more or less the same meaning is given. The very first meaning noted there is: "the action of using something; the f…

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