PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

1(3), Bangalore dated 31.03.2013, further an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 153D read with Section 144 for the assessment

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

1(3), Bangalore dated 31.03.2013 an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read with Section 144 of the IT Act for assessment years 2005-06 to 2010-11 and under Section 154D read with Section 144 for the assessment year

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowance made under Section 40(a)(1) of the Act for the sum of 5 Rs.7,29,13,934/- by holding that the income of the non-residents by way of commission cannot be considered as accrued or arisen or deemed to accrue or arise in India as the services of such agents were rendered or utilized outside India

COMMISSIONER OF INCOME TAX-III vs. M/S SYNDICATE BANK

The appeals are disposed of

Bench: ALOK ARADHE,RAVI V HOSMANI

disallowing an amount of Rs.192,53,21,426/- on reversal of interest pertaining to earlier years as deduction out of current years income and added back to interest on zero coupon bonds to the tune of RS.1,03,53,095/- along with other additions/disallowance in computation of regular income/book profit. It was held that as per section 36(1)(viia

THE COMMISSIONER OF INCOME-TAX vs. M/S LUWA INDIA PVT LTD

Bench: RAVI MALIMATH,N.KUMAR

vi) of sub- section (1) of section 9; By Finance Act, 2010, the said provision is substituted by the following: Substituted by the Finance Act, 2010, w.e.f. 01.04.2010. Prior to its substitution, proviso as substituted by the Finance Act, 2008, w.r.e.f. 01.04.2005, read as under: 12 “Provided that where in respect of any such sum, tax has been deducted

PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

9(1)(vi) of the Act and since, no TDS was deduction under Section 195 of the Act on the aforesaid payment, therefore, disallowance

PR. COMMISSIONER OF vs. M/S TALLY SOLUTIONS PVT LTD.,

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

9(1)(vi) of the Act and since, no TDS was deduction under Section 195 of the Act on the aforesaid payment, therefore, disallowance

PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

9(1)(vi) of the Act and since, no TDS was deduction under Section 195 of the Act on the aforesaid payment, therefore, disallowance

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

9(1)(i) of the Act or the manner in which said income is to be determined as is reasonably attributable to the operations carried out in India. 18. It is relevant to refer to Sub-sections (1) and (2) of Section 92CD of the Act. The same reads as under: "92CD. (1) Notwithstanding anything to the contrary contained

M/S GOOGLE IRELAND LIMITED vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

THE PR COMMISSIONER OF INCOME TAX vs. M/S GOOGLE INDIA PRIVATE LTD

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

disallowance under Section 40(a)(i) of the IT Act was made on account of non-deduction of tax at source for the sums payable by the appellant to Google Ireland under the Distribution 7 Agreement. The assessing officer vide common order dated 22.2.2013 for the assessment years 2007-08 to 2012-13 passed an order under Section 201(1