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

Section 9(1) (vii) (b). Thus, even assuming that the payments for such maintenance repairs were in the nature of fees for technical services, it would not be chargeable to tax. ********* ******* ***** As per this chart the leasing revenues earned in foreign exchange were 100%, 99.79% and 99.86% for the Financial Years 1997-98, 1998-99 and 1999-2000, respectively. This

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3, vs. SHANGHAI ELECTRIC GROUP CO. LTD.

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

Section 9 of the Arbitration and Conciliation Act, 1996 (hereinafter referred to as „Act‟) seeking interim reliefs. Prayers sought in OMP (I) (COMM) 460/2018 are as under:- “(a) Direct the Respondents to furnish security to a tune of USD 34,723,013 being the Offshore Supply Price, by way of an unconditional and irrevocable bank guarantee in favour

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL-3 vs. HFCL INFOTEL LTD.

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

Section 9 of the Arbitration and Conciliation Act, 1996 (hereinafter referred to as „Act‟) seeking interim reliefs. Prayers sought in OMP (I) (COMM) 460/2018 are as under:- “(a) Direct the Respondents to furnish security to a tune of USD 34,723,013 being the Offshore Supply Price, by way of an unconditional and irrevocable bank guarantee in favour

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

DCIT (INTERNATIONAL TAXATION), GURGAON vs. M/S. MSV INTERNATIONAL INC., GURGAON

In the result appeal of the revenue is dismissed

Bench: Smt Diva Singh & Shri R.K. Panda

depreciation, various restrictions placed under section 36, proviso to section 37 regarding disallowance of unlawful expenses, limitation u/ s 40(a)(i) and 43B etc. The limitation referred in Article 7(3) does not mean that income is to be taxed under presumptive scheme of computation u/ s 44D. It would Practically mean going back to article

DDIT, NEW DELHI vs. M/S. MSV INTERNATIONAL INC., GURGAON

In the result appeal of the revenue for both the years are dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiddit, Msv International Inc., Circle-3(2), International D-7, South City-I, Taxation, New Delhi Vs. Gurgaon Pan:Aadcm1304M (Appellant) (Respondent) Ddit, Msv International Inc., Circle-3(2), Room No.411, D-7, South City-I, Vs. International Taxation, Drum Gurgaon Shaped Building, Pan:Aadcm1304M New Delhi (Appellant) (Respondent)

depreciation, various restrictions placed under section 36, proviso to section 37 regarding disallowance of unlawful expenses, limitation u/s 40(a)(i) and 43B etc .The limitation referred in Article 7(3) does not mean that income is to be taxed under presumptive scheme of computation u/s 44D. It would practically mean going back to article 12(2) of the treaty

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

depreciation, mobile expenditure and telephone expenditure to the extent of 20%. 3. Aggrieved against this, the assessee preferred appeal before Ld.CIT(A) who after considering the submissions, partly allowed the appeal. Thereby, Ld.CIT(A) deleted the addition made on account of non-deduction of tax and restricted the addition to the extent of 10% of the expenditure. 4. Aggrieved against

M/S ACTIVE SECURITIES LIMITED,NEW DELHI vs. ITO, NEW DELHI

The appeals are allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

9 read with section 6(iii)." 13. In the present case, the assessee is engaged in building activities. It argues that flats are held as part of its inventory of stock-in-trade, and are not let out. The further argument is that unlike in the other instances, where such builders let out flats, here there is no letting

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

depreciation, investment losses, deductible expenses, carry forward and set-off losses, etc. However, deviations are made by DTAA in cases of royalty, interest, etc. Such deviations are also made under the IT Act (for example Sections 44-BB, 44-BBA, etc.). Under the impugned ruling delivered by AAR, remuneration to MSAS was justified by a transfer pricing analysis and, therefore

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

depreciation, investment losses, deductible expenses, carry forward and set-off losses, etc. However, deviations are made by DTAA in cases of royalty, interest, etc. Such deviations are also made under the IT Act (for example Sections 44-BB, 44-BBA, etc.). Under the impugned ruling delivered by AAR, remuneration to MSAS was justified by a transfer pricing analysis and, therefore

TURNER BROADCASTING SYSTEMASIA PACIFIC, INC.,NEW DELHI vs. DDIT, NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

depreciation, investment losses, deductible expenses, carry forward and set-off losses, etc. However, deviations are made by DTAA in cases of royalty, interest, etc. Such deviations are also made under the IT Act (for example Sections 44-BB, 44-BBA, etc.). Under the impugned ruling delivered by AAR, remuneration to MSAS was justified by a transfer pricing analysis and, therefore

TURNER BROADCASTING SYSTEM ASIA PACIFIC, INC.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

depreciation, investment losses, deductible expenses, carry forward and set-off losses, etc. However, deviations are made by DTAA in cases of royalty, interest, etc. Such deviations are also made under the IT Act (for example Sections 44-BB, 44-BBA, etc.). Under the impugned ruling delivered by AAR, remuneration to MSAS was justified by a transfer pricing analysis and, therefore