GULF PIPING COMPANY WLL,UNITED ARAB EMIRATES vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

Permanent Establishment in India (PE) of the non- resident in India, the same cannot be taxed. We have Bangalore in the case of ABB FZ-LLC which was a case rendered in the context of DTAA between India and UAE. The decision of the CIT(A) is in line with the decision referred to above and is a correct interpretation

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing so, the ld AO rejected the books of account and rejected book results shown by the assessee. In AY 2008-09, the Tribunal remanded the matter to the file of the ld AO with regard to determination of profit for outsource supply vide its order

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

permanent or temporary nature? 7) Whether the land, though entered in revenue records, had never been actually used for 8 Devendra Dutt Pant agriculture, that is, it had never been ploughed or tilled? Whether the owner meant or intended to use it for agricultural purposes? 8) Whether the land was situate in a developed area? Whether its physical characteristics, surrounding