HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

1)(vii)(b) of the Act carves out a second exception to the taxability of FTS paid by a resident, wherein the fee for technical services payable in respect of services utilized for the purpose of making or earning any income from any source outside India is not an Income within the ambit of section 9

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

1)(vii)(b) of the Act carves out a second exception to the taxability of FTS paid by a resident, wherein the fee for technical services payable in respect of services utilized for the purpose of making or earning any income from any source outside India is not an Income within the ambit of section 9

QAI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-14(1), NEW DELHI

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumar, Ms. Madhumita Roy

Section 9(1)(vii)(b) of the Act. Reliance is also placed on the following judicial pronouncements in this regard:  DCIT Vs. M/s Hofincons Infotech and Industrial Services Pvt. Ltd. 2015 (3) TMI 876 - ITAT Chennai Dated: -18-8- 2014 “7. We have heard both parties, perused the case file and the judicial precedents quoted hereinabove. The question before

QAI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-14(1), NEW DELHI

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumar, Ms. Madhumita Roy

Section 9(1)(vii)(b) of the Act. Reliance is also placed on the following judicial pronouncements in this regard:  DCIT Vs. M/s Hofincons Infotech and Industrial Services Pvt. Ltd. 2015 (3) TMI 876 - ITAT Chennai Dated: -18-8- 2014 “7. We have heard both parties, perused the case file and the judicial precedents quoted hereinabove. The question before

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

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

1)(vii) of tint Income Tax Act, 1961 will be fully applicable. It has already earlier been held that Consultancy Services are taxable in India as per the provisions of Section 9(l)(vii). The assessee was therefore required to deduct TDS

MR. SANJEEV GUPTA,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, ground No. 3 and 4 With respect to the disallowance of export commission of the appeal of the assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishisanjeev Gupta, Vs. Addl. Cit, E-31, Kamla Nagar, Range-20, New Delhi New Delhi Pan:Ahcpg7326A (Appellant) (Respondent)

Section 9 (1) (vii) of the Act and therefore TDS certificate is essential. 6. Whether this contention is correct, is the issue

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] 201(1)/201(1A) of the Act, which is impugned in the present appeal, holding therein that interconnect charges paid by the appellant to foreign telecom operators were in the nature of fee for technical services under section 9(1)(vii

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

1)(vii)(b). The AO further rejected the assessee's plea that the business of aircraft leasing was carried on outside India. The assessee's alternate plea that in any case the payments made to residents of USA, UK, Israel, Netherlands, Singapore and Thailand could be taxed as business profits only and not as fees for technical services keeping