“equalisation levy”

ACRONIS ASIA PTE LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )RANGE-1(1)(1), MUMBAI

In the result, the appeal filed by the assessee is\nallowed in the aforesaid terms

reasoning or analytical\nbasis for such recharacterization. Ld. AO observed that\nassessee has neither submitted any copy of agreement nor\nproof in respect of equalisation levied having been paid and\ntherefore, in absence of any documentary evidences he held\nthat claim of exemption u/s.10(50) cannot be given ... larger\nbusinesses, the software often needs bespoke installation and\nimplementation strategies, which require human intervention in\nthe design and execution of these setups.\n7. Equalisation Levy (EL): The Applicant failed to provide\nadequate evidence of El payment. The claim that the levy was\n\"in process\" does not suffice

JEPPESEN GMBH,GERMANY vs. ACIT, INTERNATION TAXATION, CIRCLE-3(1)(1), MUMBAI, MUMBAI, MAHARASHTRA

In the result, the appeal of the assessee is partly allowed

assessee had altered its treatment by, according to the Assessing Officer, not offering the income as royalty at the treaty rate and instead paying equalisation levy at two per cent on a portion of receipts. It was also noticed by the Assessing Officer that the assessee had claimed exempt income ... deleted.\n\n18. Since we have deleted the addition on the principal issue, the issue raised in Ground No. 5 relating to refund/credit of equalisation levy becomes purely academic.\n\n19. Ground relating to interest under section 234B is consequential. Other grounds were not argued or pressed and are dismissed

CA (SINGAPORE) PTE LTD ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE 2(1)(1), MUMBAI

In the result, the appeal of the assessee partly allowed

Bench: Ms Suchitra Kamble & Shri Girish Agrawalca(Singapore) Pte Ltd., The Assistant Vs. C/O Ca (India) Technologies Commissioner Of India Private Limited, Income Tax, S1 Wipro Sez, International Taxation, Doddathogur Village, Circle2 (1)(1), Begur Hobli, Mumbai. Electronic City, Bangalore-560100. [Pan :Aahcc8349Q] (Appellant) .. (Respondent) Appellant By : Shri Ajit Jain, With Shri, Siddesh Chaugule, Ars Respondent By: Shri Krishna Kumar, Sr. Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 16.12.2025 O R D E R Per Suchitra Kamble:

maintenance. 3.6 The Ld. AO and Hon'ble' DRP grossly erred in disregarding the Appellant's submissions that the relevant consideration was chargeable to Equalisation Levy provisions. 4. Erroneous levy of surcharge and health & education cess 4.1 The Ld. AO has erred in levying surcharge and health & education cess

MICHAEL PAGE INTERNATIONAL PTE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) -3(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed

nfailed to follow the specific directions issued by the Ld. DRP by not granting\nthe credit of taxes paid as Equalisation Levy ('EL') of INR 31,18,480 while\ncomputing the tax demand, thereby violating the provisions of section\n144C(13) of the Act.\nThe Appellant humbly prays that ... regards ground no. 3, raised in assessee's appeal, the learned AR\nsubmitted that the assessee, suo moto, discharged the equalisation levy at\nthe rate of 2% on its income earned from rendering management support\nservices, and the assessee is not claiming any refund of the same. Thus, the\nlearned