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 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

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

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

W SERVE TECHNOLOGIES PRIVATE LIMITED,GURGAON vs. ACIT, CPC-TDS, GHAZIABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

3) of section 200 of the Act enable the deductor to furnish TDS correction statement and consequently, section 200A of the Act allows processing of the TDS correction statement. However, currently, there does not exist any provision for allowing a collector to file correction statement in respect of TCS statement which has been furnished. It is, therefore, proposed to amend

W SERVE TECHNOLOGIES PRIVATE LIMITED,GURGAON vs. ACIT, CPC-TDS, GHAZIABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

3) of section 200 of the Act enable the deductor to furnish TDS correction statement and consequently, section 200A of the Act allows processing of the TDS correction statement. However, currently, there does not exist any provision for allowing a collector to file correction statement in respect of TCS statement which has been furnished. It is, therefore, proposed to amend

M/S. SAMIKARAN LEARNING PVT. LTD.,DELHI vs. DCIT, DELHI

The appeals of the assessee are allowed

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

195 to 196D of the Act were various provisions for deducting tax at source. Section 199 of the Act provides credit of tax deducted at source and section 200 of the Act lays down the duties of person responsible to deduct the tax. He further stressed that it was mandatory that after deduction, the deductor shall

M/S. SAMIKARAN LEARNING PVT. LTD.,DELHI vs. DCIT, DELHI

The appeals of the assessee are allowed

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

195 to 196D of the Act were various provisions for deducting tax at source. Section 199 of the Act provides credit of tax deducted at source and section 200 of the Act lays down the duties of person responsible to deduct the tax. He further stressed that it was mandatory that after deduction, the deductor shall

M/S. HAMIR REAL ESTATE PVT. LTD.,DELHI vs. ITO (TDS), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri G. D. Agrawal & Shri Amit Shukla

3)(ii) of the Act and the decision in CIT v. Idea Cellular Ltd. (supra) to justify initiation of the proceedings in the present case against the petitioner is misconceived." 16. The court was conscious of the absence of any limitation period in respect of payments to non-residents, for the purpose of Section 195 read with Section

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

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

195 to 196D of the Act were various provisions for deducting tax at source. Section 199 of the Act provides credit of tax deducted at source and section 200 of the Act lays down the duties of person responsible to deduct the tax. He further stressed that it was mandatory that after deduction, the deductor shall

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

195 to 196D of the Act were various provisions for deducting tax at source. Section 199 of the Act provides credit of tax deducted at source and section 200 of the Act lays down the duties of person responsible to deduct the tax. He further stressed that it was mandatory that after deduction, the deductor shall

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

195 to 196D of the Act were various provisions for deducting tax at source. Section 199 of the Act provides credit of tax deducted at source and section 200 of the Act lays down the duties of person responsible to deduct the tax. He further stressed that it was mandatory that after deduction, the deductor shall

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. Alternatively, the payee can also resort to section 195(3) of the Income Tax Act read with rules 37BB

SERCO INDIA PVT. LTD.,PUNE vs. DCIT, GURGAON

In the result, appeal filed by the Assessee stands allowed

Bench: Shrianil Chaturvedi, Am & Shri N. K. Choudhry, Jm

3. TDS was required to be deducted under section 192 or 195. 4. TDS in section 192 is at higher

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

3). Perhaps for this reason, the AO did not take recourse to the provisions of Article 9 of the respective DTAAs. 18. As regards the transactions entered into by the respondent/assessee with the remaining two entities, i.e., MC Metal (Thailand) and Metal One (Singapore), the respondent/assessee does not press the argument of equal treatment as the DTAAs entered into

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

The appeals are dismissed against the

3). Perhaps for this reason, the AO did not take recourse to Digitally Signed By:PRAMOD KUMAR VATS Signing Date:08.09.2025 17:15:12 Signature Not Verified ITA 329/2025 & 332/2025 Page 8 of 19 the provisions of Article 9 of the respective DTAAs. 18. As regards the transactions entered into by the respondent/assessee with the remaining two entities