DDIT, NEW DELHI vs. M/S SCORPION COURAGEOUS LTD.,, NEW DELHI

In the result, the Cross Objection of the assessee is partly allowed

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

ADIT, NEW DELHI vs. M/S. PARPOOL LTD., NEW DELHI

In the result, solitary ground of appeal of the revenue is dismissed

Bench: Shri H S Sidhu & Shri Prashant Maharishi

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

ROLLS ROYCE MILITARY AERO ENGINES LTD vs. DDIT INT. TAXATION CIRCLE 2 (1),

In the result all the five appeals of the assessee are partly allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

ROLLS ROYCE MILITARY AERO ENGINES LTD vs. DDIT INTL. TAXATION CIRCLE-2 (1),

In the result all the five appeals of the assessee are partly allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

DCIT, NEW DELHI vs. M/S XANSA INDIA LTD., NOIDA

In the result appeal of the revenue is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid

ACIT, CIRCLE- 47(1), NEW DELHI vs. J. KISHORE EXPORTS, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2014-15] Acit, Vs J.Kishore Exports, Circle-47(1), 558, Katra Ishwar Bhawan, New Delhi. Khari Baoli, New Delhi-110006. Pan-Aagfj9713M Appellant Respondent Appellant By Sh. Ashwani Kalia, Ca Respondent By Sh. Umesh Takyar, Sr.Dr Date Of Hearing 01.11.2021 Date Of Pronouncement 23.11.2021

TDS on commission payments to non- residents. However, if any sum is not chargeable as income of the recipient, then recourse is available to the payer under section 195(2

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195-A 47. The Finance Act 2002 sought to simplify the scheme for taxation of perquisites and gave the employer the option to pay taxes on the whole or part value of perquisites (excluding those provided for by way of monetary payment) without any deduction from the income of the employee. Simultaneously, the tax paid on such non-monetary perquisites

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195-A 47. The Finance Act 2002 sought to simplify the scheme for taxation of perquisites and gave the employer the option to pay taxes on the whole or part value of perquisites (excluding those provided for by way of monetary payment) without any deduction from the income of the employee. Simultaneously, the tax paid on such non-monetary perquisites

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195-A 47. The Finance Act 2002 sought to simplify the scheme for taxation of perquisites and gave the employer the option to pay taxes on the whole or part value of perquisites (excluding those provided for by way of monetary payment) without any deduction from the income of the employee. Simultaneously, the tax paid on such non-monetary perquisites

PRINCIPAL COMMISSIONER OF INCOME TAX- 04 DELHI vs. MITSUBISHI CORPORATION (INDIA) PVT LTD

The appeal is dismissed against the Revenue

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

TDS) that the question of making an order under Section 195 (2) will arise. While deciding the scope of Section

PRINCIPAL COMMISSIONER OF INCOME TAX - 4 DELHI vs. MITSUBISHI CORPORATION (INDIA) PVT LTD

The appeals are dismissed against the

TDS) that the question of making an order under Section 195 (2) will arise. While deciding the scope of Section

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

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

TDS certificates\nissued for FY 16-17 on sample basis, are enclosed as Enclosure-IV.\nThus, our submission is that, the entire collection expenditure, including provision\nmade for the purpose of business and services rendered by collection vendors\nduring the year 2016-17. is allowable as business expenditure to the assessee.\nTherefore, the question disallowance or making any addition

NIIT FOUNDATION,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri K.N.Charyniit Foundation, Vs. Cit(E), Plot No. 8, Balaji Estate, New Delhi Sudarshan Munjal Marg, Kalkaji, New Delhi Pan: Aacan3951E (Appellant) (Respondent)

TDS of Rs.190360 has been made by it.Thus it is clear that the payment is made for the use of infrastructure and support services rendered by the assessee. The assessee cannot claim that it is authorized agency for running of NSDC course and thus the argument that its courses are approved by government authorities are factually incorrect. 7.2 The assessee

ITO, NEW DELHI vs. SH. KULBEER SINGH, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishiito, Vs. Kulbeer Singh, Ward-26(1), H-432, Vikas Puri, New Delhi New Delhi Pan: Amqps5847P (Appellant) (Respondent)

TDS liability on such commission is an offshoot from its chargeability to Income tax under Section 5(2) of the Act. 5.3 Section 195

CIENA INDIA PVT. LTD.,GURGAON vs. ITO, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 195(2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring

CIENA INDIA PVT. LTD.,GURGAON vs. ITO, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 195(2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring

THE PR. COMMISSIONER OF INCOME TAX-9 vs. UNISION HOTELS LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

TDS) that the question of making an order under Section 195 (2) will arise. While deciding the scope of Section