PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS under that section arises only if the assessee pays or credits “any sum chargeable under the provisions of this act”. Thereafter, he carried us to section 9(1)(i) which prescribes the chargeability/taxability of ‘business income’ in India. He submitted that in the present case, section 9(1)(i) is not applicable for the certain reasons, namely

PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS under that section arises only if the assessee pays or credits “any sum chargeable under the provisions of this act”. Thereafter, he carried us to section 9(1)(i) which prescribes the chargeability/taxability of ‘business income’ in India. He submitted that in the present case, section 9(1)(i) is not applicable for the certain reasons, namely

PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS under that section arises only if the assessee pays or credits “any sum chargeable under the provisions of this act”. Thereafter, he carried us to section 9(1)(i) which prescribes the chargeability/taxability of ‘business income’ in India. He submitted that in the present case, section 9(1)(i) is not applicable for the certain reasons, namely

M/S TESLA TRANSFORMERS ,BHOPAL vs. ITO(INTERNATIONAL TAXATION),, BHOPAL

In the result, Ground Numbers 1 to 4 of assessee’s appeal are dismissed

TDS on the amount which was attributable to operations being carried out in India. The AO further noted that Rule 10 of the Income Tax Rules, 1962 provides that AO can attribute such percentage of the turnover so accruing or arising as he may consider to be reasonable/ in such manner as the AO may deem suitable. Grossing

SNAP COMPUTER SYSTEMS PVT. LTD.,INDORE vs. ITO (INTERNATIONAL TAXATION & TRANSFER PRICING), BHOPAL

Bench: Shri Kul Bharat & Shri Manish Borad

TDS thereon remitted in per Section @25.75% u/s Rs. 195A of the incl. cess 201(1A) till Act date 1 Systems

SNAP COMPUTER SYSTEM (P) LTD.,INDORE vs. ITO (INTER TAXATION & TRANSFER PRICING), BHOPAL

Bench: Shri Kul Bharat & Shri Manish Borad

TDS thereon remitted in per Section @25.75% u/s Rs. 195A of the incl. cess 201(1A) till Act date 1 Systems

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

TDS @ remittance thereon remitted of amount per 41.2% u/s in Rs. remitted section incld. cess 201(1A) 195A of the Act Buhler

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

TDS @ remittance thereon remitted of amount per 41.2% u/s in Rs. remitted section incld. cess 201(1A) 195A of the Act Buhler

RSV GLOBAL,RAIPUR vs. INCOME TAX OFFICER (IT & TP), BHOPAL

In the result, the appeal filed by the assessee in ITA

Bench: Shri Kul Bharat & Shri Manish Borad

195A of the I.T. Act. 2. Facts in brief are that the assessee is a firm engaged in trading activity of yellow peas, grains, etc. The A.O. observed that as per the information available on the system, the assessee filed form No.15CA regarding remittance of various payments to non-residents. The A.O. issued a letter dated 6.11.2015 for verification