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

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

9 of the impugned order, the Commissioner records that the violation of section 11 & 13 of the Act would result in forfeiture of exemption not only for the year in which such transactions occur but also for the years when such arrangement continues to be in force. In our considered opinion, such an approach of the Commissioner is quiet misdirected

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

9(1){uii)of the act and its receipt from NHAI project was taxable as normal business profits. Questions no.(i) framed in para 4 is accordingly answered in negative and in favor of appellant. As a result, the question no.(ii)becomes inconsequential. 7.4 However, let us examine the alternate plea of the appellant also regarding applicability of section

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

9. After an in-depth study of the entire case record, on a patient hearing of both the sides and after reading the case law cited at length, our observations and findings on the matter are as follows. Before giving our observation and finding, it has been deemed proper to quote ss. 150 and 151 as it is, as under

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

9. After an in-depth study of the entire case record, on a patient hearing of both the sides and after reading the case law cited at length, our observations and findings on the matter are as follows. Before giving our observation and finding, it has been deemed proper to quote ss. 150 and 151 as it is, as under

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

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 the I.T. Act, 1961 defines Fees for Technical Services which means any consideration including any consideration for rendering any managerial, technical or consultancy [including the provision of services of technical or other personnel] but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient 58 ITA.No.3377 to 3383/Del./2018

COMMISSIONER OF INCOME TAX DELHI I vs. ANANT RAJ INDUSTRIES P. LTD.

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under

CIT vs. NEGOLICE INDIA PVT LTD

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under

COMMISSIONER OF INCOME TAX DELHI I vs. ANANT RAJ INDUSTRIES P. LTD.

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under

COMMISSIONER OF INCOME TAX vs. BRIJBASI ART PRESS LIMITED

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under

COMMISSIONER OF INCOME TAX vs. BIOSEED RESEARCH (INDIA) PVT. LIMITED

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under

COMMISSIONER OF INCOME TAX DELHI-1 vs. ALLIED STRIPS LTD

The appeals are dismissed

9. On the strength of this Circular, it was contended that reduction of MAT credit prior to computation of interest under sections 234B and 234C is permissible only after 01.04.2007, that is, for assessment year 2007-2008 onwards. Since all these appeals relate to prior assessment years, MAT credit cannot be set off prior to the computation of interest under