ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

M/S. ARIBA INC.,GURGAON vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

M/S. ARIBA INC.,GURGAON vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

ARIBA INC,NEW DELHI vs. ADIT (INTL TAXATION), NEW DELHI

In the result, all these appeals filed by the assessee stand partly

44D read with section 115A(1)(b) of the ITA. The balance amount of the royalty (which was held to be not attributable to the DAPE) was to be taxed at 15% under Article 12 of the India-US DTAA. However, the CIT (A) granted relief on the additions made by the AO in these AYs on account of notional

DCIT, INTERNATIONAL TAXATION, CIRCLE GURGAON , GURUGRAM vs. LUMMUS TECHNOLOGY HEAT TRASFER BV- INDIA BRANCH OFFICE , GURGAON

In the result, the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

transfer pricing order under section 92CA(3) of the Act. Disallowance of proportionate expenses 4,31,695 in relation to income taxable under section 44D

DCIT, INTERNATIONAL TAXATION, CIRCLE GURGAON , GURUGRAM vs. LUMMUS TECHNOLOGY HEAT TRASFER BV- INDIA BRANCH OFFICE , GURGAON

In the result, the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

transfer pricing order under section 92CA(3) of the Act. Disallowance of proportionate expenses 4,31,695 in relation to income taxable under section 44D

DCIT, INTERNATIONAL TAXATION, CIRCLE GURGAON , GURUGRAM vs. LUMMUS TECHNOLOGY HEAT TRASFER BV- INDIA BRANCH OFFICE , GURGAON

In the result, the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

transfer pricing order under section 92CA(3) of the Act. Disallowance of proportionate expenses 4,31,695 in relation to income taxable under section 44D

DIRECTOR OF INCOME TAX vs. INFRASOFT LTD

44D read with Section 115A. 14. The CIT(A) vide the order dated 10.01.2008, rejected the submissions of the Assessee company. The CIT(A) in his order noted that the Assessee company was engaged in licensing of MX software which is an engineering friendly tool for designing all types of road projects to Indian customers. He noted the clarification

SABRE DECISION TECHNOLOGIES INTERNATIONAL LLC,NEW DELHI vs. ACIT, INTERNATIONAL TAXATION, CIRCLE 3(1)(2), NEW DELHI

In the result, the appeal of the revenue is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

price and the right time while being assured of complying with industry standards and regulations when using our solution. Our product merchandising solution will enable you to: Increase Revenue • Provides opportunity to generate incremental revenue through the sale of ancillary products and services • Provides connection to the largest global travel marketplace with access to more than 55,000 agency locations

ACIT, INTERNATIONAL TAXATION, CIRCLE 3(1)(2), NEW DELHI vs. SABRE DECISION TECHNOLOGIES INTERNATIONAL LLC, USA

In the result, the appeal of the revenue is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

price and the right time while being assured of complying with industry standards and regulations when using our solution. Our product merchandising solution will enable you to: Increase Revenue • Provides opportunity to generate incremental revenue through the sale of ancillary products and services • Provides connection to the largest global travel marketplace with access to more than 55,000 agency locations