DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. ACIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWERE IRELAND LIMITED,DUBLIN 24, IRELAND vs. DCIT CIRCLE- 1(1)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil