DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

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

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

u/s.\n144C(1) of the act holding that IUC received by the assessee are\nin the nature of 'Royalty' under the provisions of the act, as well\nunder the India-Japan DTAA.\n2.7 Aggrieved by the order of the Ld.AO, the assessee filed\nobjections before the DRP. The DRP after hearing the\nsubmissions of the assessee, passed direction dated

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

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

u/s.\n144C(1) of the act holding that IUC received by the assessee are\nin the nature of 'Royalty' under the provisions of the act, as well\nunder the India-Japan DTAA.\n2.7 Aggrieved by the order of the Ld.AO, the assessee filed\nobjections before the DRP. The DRP after hearing the\nsubmissions of the assessee, passed direction dated

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

In the result, both the appeals filed by the assessee for both\nthe years under consideration stands partly allowed

147 of the act by holding\nthe income received by assessee from the Indian company as\nroyalty u/s. 9(1)(vi) of the act r.w.Explanation 2 and 6.\n4.3 Against the draft assessment order, the assessee filed the\nobjections before the DRP. The DRP upheld the view of the\nLd.AO by relying on the decision of Hon'ble Madras High