M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

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

ii) of the said explanation also use identical terms. 5.2.2 The words which surround the word 'process' in clauses (i) to (iii) of Explanation 2 to section 9(1) (vi), refer to various species of intellectual properties such as patent, invention, model, design, formula, trade mark etc. The expression 'similar property' used at the end of the list, further fortifies

SUPREME TRANSPORT COMPANY,INDORE vs. ITO TDS-II, INDORE

In the result, all the appeals filed by the assessees are allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

35,00,000/-, the assessee' contention has Page 18 of 23 M/s. Supreme Transport Company ITA No. 914 & 917/Ind/2024 – AY 2013-14 Financial Year 2012-13 / Q2 – 24Q & Q3-24Q] been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs. 50 lacs and therefore, provision

SUPREME TRANSPORT COMPANY,INDORE vs. ITO TDS-II, INDORE

In the result, all the appeals filed by the assessees are allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

35,00,000/-, the assessee' contention has Page 18 of 23 M/s. Supreme Transport Company ITA No. 914 & 917/Ind/2024 – AY 2013-14 Financial Year 2012-13 / Q2 – 24Q & Q3-24Q] been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs. 50 lacs and therefore, provision

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

ii) of the said explanation also use identical terms. 5.2.2 The words which surround the word 'process' in clauses (i) to (iii) of Explanation 2 to section 9(1) (vi), refer to various species of intellectual properties such as patent, invention, model, design, formula, trade mark etc. The expression 'similar property' used at the end of the list, further fortifies

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

ii) of the said explanation also use identical terms. 5.2.2 The words which surround the word 'process' in clauses (i) to (iii) of Explanation 2 to section 9(1) (vi), refer to various species of intellectual properties such as patent, invention, model, design, formula, trade mark etc. The expression 'similar property' used at the end of the list, further fortifies

BMG CALCUTTAWALA JEWELLERS PVT. LTD.,INDORE vs. AO CPC (TDS), ITO TDS(1) INDORE, INDORE

Appeals are allowed\"

35,00,000/-, the assessee' contention has\nbeen that it was not required to deduct TDS, because the\npayments made to each seller was less than the prescribed limit\nof Rs.50 lacs and therefore, provision of section 194IA was not\napplicable. The demand has been raised by the department u/s\n200 in terms of failure to comply with Section 200A

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

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

section 9(1)(vii) had no application at all. The assessee also submitted that the foreign supplier had deputed his technical persons for installation and no money was separately paid on that account. However, the AO was not satisfied with submission of assessee who insisted that the amount of installation charges was separately mentioned in all documents. Ultimately

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

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

section 9(1)(vii) had no application at all. The assessee also submitted that the foreign supplier had deputed his technical persons for installation and no money was separately paid on that account. However, the AO was not satisfied with submission of assessee who insisted that the amount of installation charges was separately mentioned in all documents. Ultimately

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

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

section 9(1)(vii) had no application at all. The assessee also submitted that the foreign supplier had deputed his technical persons for installation and no money was separately paid on that account. However, the AO was not satisfied with submission of assessee who insisted that the amount of installation charges was separately mentioned in all documents. Ultimately

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1

M/S. STAR DELTA TRANSFORMERS LTD.,BHOPAL vs. THE ITO ( TDS) -2, BHOPAL

The appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

TDS) does not arise in the present case as there is no income per se and taxability of income per se in the present scenario. The Ld. A.R. relied upon the notifications issued under the Income Tax Act, 1961 wherein both these institutes have been approved by the Central Government for the purpose of Clause 2 of sub-Section 1