HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

permanence. It is emphasized that to constitute a ‘fixed place of business’, the foreign enterprise must have at its disposal certain premises or part thereof. Philip Baker, in his commentary on Double Taxation Conventions (Third Edition), states that the fixed place is very much that of a physical location, i.e., one must be able to pinpoint to a physical location

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

permanence. It is emphasized that to constitute a ‘fixed place of business’, the foreign enterprise must have at its disposal certain premises or part thereof. Philip Baker, in his commentary on Double Taxation Conventions (Third Edition), states that the fixed place is very much that of a physical location, i.e., one must be able to pinpoint to a physical location

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

permanence. It is emphasized that to constitute a ‘fixed place of business’, the foreign enterprise must have at its disposal certain premises or part thereof. Philip Baker, in his commentary on Double Taxation Conventions (Third Edition), states that the fixed place is very much that of a physical location, i.e., one must be able to pinpoint to a physical location

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

permanent establishment and business connection of the assessee. Hence, we remit entire issue to the file of Assessing Officer to verify the claim and pass the order. This ground of the Revenue is allowed for statistical purpose. Now we adjudicate ITA No.439/Mds/2010 of assessment 20. years 2006-2007:- The first ground raised in this appeal is with regard to Employee

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

permanent establishment and business connection of the assessee. Hence, we remit entire issue to the file of Assessing Officer to verify the claim and pass the order. This ground of the Revenue is allowed for statistical purpose. Now we adjudicate ITA No.439/Mds/2010 of assessment 20. years 2006-2007:- The first ground raised in this appeal is with regard to Employee

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

permanent establishment and business connection of the assessee. Hence, we remit entire issue to the file of Assessing Officer to verify the claim and pass the order. This ground of the Revenue is allowed for statistical purpose. Now we adjudicate ITA No.439/Mds/2010 of assessment 20. years 2006-2007:- The first ground raised in this appeal is with regard to Employee

M.R.M.PLANTATIONS P. LTD.,CHENNAI vs. DCIT, MADURAI

In the results, the appeals of the assessee in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.Nos.2772 & 2773/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06 & 2006-2007. M/S. M.R.M. Plantations P. Ltd, Vs. The Deputy Commissioner Of No.40, M.R.M Arcade, Income Tax, Amman Sannathi Street, Circle Ii, Karaikudi Madurai [Pan Aaccm 9058R ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

permanent establishment the income from the plantation would be taxable only in Malaysia and not in India. The assessee already filed its return of income and the return filed for all these assessment years which was kept in record. Accordingly, in our opinion the order of the Commissioner of Income Tax (Appeals) is to be confirmed. This appeal

M.R.M.PLANTATIONS P. LTD.,CHENNAI vs. DCIT, MADURAI

In the results, the appeals of the assessee in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.Nos.2772 & 2773/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06 & 2006-2007. M/S. M.R.M. Plantations P. Ltd, Vs. The Deputy Commissioner Of No.40, M.R.M Arcade, Income Tax, Amman Sannathi Street, Circle Ii, Karaikudi Madurai [Pan Aaccm 9058R ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

permanent establishment the income from the plantation would be taxable only in Malaysia and not in India. The assessee already filed its return of income and the return filed for all these assessment years which was kept in record. Accordingly, in our opinion the order of the Commissioner of Income Tax (Appeals) is to be confirmed. This appeal

DCIT, KARAIKUDI vs. M.R.M.PLANTATIONS P. LTD., KARAIKUDI

In the results, the appeals of the assessee in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.Nos.2772 & 2773/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06 & 2006-2007. M/S. M.R.M. Plantations P. Ltd, Vs. The Deputy Commissioner Of No.40, M.R.M Arcade, Income Tax, Amman Sannathi Street, Circle Ii, Karaikudi Madurai [Pan Aaccm 9058R ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

permanent establishment the income from the plantation would be taxable only in Malaysia and not in India. The assessee already filed its return of income and the return filed for all these assessment years which was kept in record. Accordingly, in our opinion the order of the Commissioner of Income Tax (Appeals) is to be confirmed. This appeal

DCIT, KARAIKUDI vs. M.R.M.PLANTATIONS P. LTD., KARAIKUDI

In the results, the appeals of the assessee in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.Nos.2772 & 2773/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06 & 2006-2007. M/S. M.R.M. Plantations P. Ltd, Vs. The Deputy Commissioner Of No.40, M.R.M Arcade, Income Tax, Amman Sannathi Street, Circle Ii, Karaikudi Madurai [Pan Aaccm 9058R ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

permanent establishment the income from the plantation would be taxable only in Malaysia and not in India. The assessee already filed its return of income and the return filed for all these assessment years which was kept in record. Accordingly, in our opinion the order of the Commissioner of Income Tax (Appeals) is to be confirmed. This appeal

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

DCIT, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

ACIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

permanent establishment in India / branch established in India / Liaison office in India. Hence, any payment made by the assessee company to such foreign insurers would not be chargeable to tax in the hands of the foreign reinsurers in India in terms of Section 195(1) of the Act. Accordingly, as stated earlier, there would be no obligation on the part