US Technology Research Pvt.Ltd. v. ACIT

61 SOT 19Income Tax Appellate Tribunal#25362 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 365,591 Indian tax judgments — from 2017 to 2017.

Judgments citing US Technology Research Pvt.Ltd. v. ACIT

The Timken Company, Kolkata vs. The DDIT, International Taxation - 3(1), Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 1268/KOL/2014[2005-06]Status: DisposedITAT Kolkata29 Nov 2017AY 2005-06

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…t clear that consideration for advisory services rendered cannot be treated as fees for included services under Article 12(4)(b). 19. The learned DR placed reliance on a decision of the ITAT Cochin Bench in the case of US Technology Research Pvt.Ltd. Vs. ACIT 61 SOT 19 (Cochin). We have perused the said decision and find that in para-37 of the order, the Tribunal has found as a fact that technology or technique was made available to the recipient. On the facts of the present case, there is no material on record to show that technology was made available and TIL was permitted to apply the technology in the sense t…

The Timken Company, Kolkata vs. A.D.I.T (International Taxation) - II, Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 2139/KOL/2013[2004-05]Status: DisposedITAT Kolkata29 Nov 2017AY 2004-05

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…t clear that consideration for advisory services rendered cannot be treated as fees for included services under Article 12(4)(b). 19. The learned DR placed reliance on a decision of the ITAT Cochin Bench in the case of US Technology Research Pvt.Ltd. Vs. ACIT 61 SOT 19 (Cochin). We have perused the said decision and find that in para-37 of the order, the Tribunal has found as a fact that technology or technique was made available to the recipient. On the facts of the present case, there is no material on record to show that technology was made available and TIL was permitted to apply the technology in the sense t…

ADIT(It)-3(1), Kolkata vs. The Timken Company, Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 387/KOL/2010[2002-03]Status: DisposedITAT Kolkata29 Nov 2017AY 2002-03

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…t clear that consideration for advisory services rendered cannot be treated as fees for included services under Article 12(4)(b). 19. The learned DR placed reliance on a decision of the ITAT Cochin Bench in the case of US Technology Research Pvt.Ltd. Vs. ACIT 61 SOT 19 (Cochin). We have perused the said decision and find that in para-37 of the order, the Tribunal has found as a fact that technology or technique was made available to the recipient. On the facts of the present case, there is no material on record to show that technology was made available and TIL was permitted to apply the technology in the sense t…

US Technology Research Pvt.Ltd. v. ACIT (61 SOT 19) — Cited in 3 Judgments | BharatTax