RRPR HOLDING PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, Grounds No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

9 Act. The AO concluded that in view of S. 139(3), the capital loss can not be carried forward unless the return showing such loss is filed under S. 139(5) of the Act, whereas the Assessee has not claimed such loss in the ROI filed under S. 139(1) of the Act and made an altogether fresh claim

ACIT, CIRCLE-7(1) vs. SYSTEM AMERICA INDIA LTD.,,

In the result, appeal of the assessee is partly allowed and that of the Department is dismissed

Bench: Shri N.K. Saini & Shri Kuldip Singh

139/- on the sale of 1000 shares of M/s Systems America India Ltd. It has also been observed that she has shown to incur short term capital loss of R s. 1,70,96,112/- on a/c of 172000 equity shares of M/s Suma Finance Ltd. (C ost Price Rs.101.25 per share and selling price Rs. 1.729 per share). From

SYSTEMS AMERICA (INDIA) LTD. vs. ADDL. COMMISSIONER OF INCOME TAX,,

In the result, appeal of the assessee is partly allowed and that of the Department is dismissed

Bench: Shri N.K. Saini & Shri Kuldip Singh

139/- on the sale of 1000 shares of M/s Systems America India Ltd. It has also been observed that she has shown to incur short term capital loss of R s. 1,70,96,112/- on a/c of 172000 equity shares of M/s Suma Finance Ltd. (C ost Price Rs.101.25 per share and selling price Rs. 1.729 per share). From

DIRECTOR OF INCOME TAX DELHI vs. M/S LUFTHANSA CARGO INDIA P .

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.K.GAUBA

TDS. With reference to payments made to residents of UK and USA, the CIT (A) held that they were not in the nature of „fees for technical or included services‟ under Article 12 of the DTAA read with the Memorandum of Understanding with USA which equally applied to the UK Treaty. Payments made to residents of USA and UK were

DIRECTOR OF INCOME TAX DELHI vs. M/S LUFTHANSA CARGO INDIA P .

TDS. With reference to payments made to residents of UK and USA, the CIT (A) held that they were not in the nature of „fees for technical or included services‟ under Article 12 of the DTAA read with the Memorandum of Understanding with USA which equally applied to the UK Treaty. Payments made to residents of USA and UK were

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

TDS, Ld. CIT(A) has passed a very elaborate and speaking order and Ld. D.R. was unable to controvert any of his findings, therefore, we do not find any infirmity in the 65 ITA.No.3377 to 3383/Del./2018 M/s. Sharda Educational Trust, Greater Noida, Uttar Pradesh. same. Similarly, Ld. CIT(A) has allowed depreciation on computer peripherals based upon various

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

SUBRAMANIAM HARIHARAN,DELHI vs. ACIT, CIRCLE-63(1), NEW DELHI

139, thirty per\ncent of such sum shall be allowed as a deduction in computing the income\nof the previous year in which such tax has been paid :\nProvided further that where an assessee fails to deduct the whole or any\npart of the tax in accordance with the provisions of Chapter XVII-B on any\nsuch

ACIT, CIRCLE-61(1), NEW DELHI vs. SUBRAMANIAM HARIHARAN, NEW DELHI

139, thirty per\ncent of such sum shall be allowed as a deduction in computing the income\nof the previous year in which such tax has been paid :\nProvided further that where an assessee fails to deduct the whole or any\npart of the tax in accordance with the provisions of Chapter XVII-B on any\nsuch

M/S GEO CONNECT LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

9. Thus if the transaction is one of leasing/hiring/letting simpliciter under which the possession of the goods, i.e., effective and general control of the goods is to be given to the customer and the customer has the freedom and choice of selecting the manner, time and nature of use and enjoyment, though within the framework of the agreement, then