DCIT, CIRCLE - 10(1), KOLKATA , KOLKATA vs. M/S. BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD., KOLKATA

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

43C of the Act. This income is to be deemed to be the profits and gains of said business chargeable of tax under the head "profits and gains" of business. However, the said provisions are applicable where the gross receipts paid or payable does not exceed Rs. 40 lakhs. iii. The Hon'ble ITAT, Kolkata Bench in the case

BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. DCIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

43C of the Act. This income is to be deemed to be the profits and gains of said business chargeable of tax under the head "profits and gains" of business. However, the said provisions are applicable where the gross receipts paid or payable does not exceed Rs. 40 lakhs. iii. The Hon'ble ITAT, Kolkata Bench in the case

BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

43C of the Act. This income is to be deemed to be the profits and gains of said business chargeable of tax under the head "profits and gains" of business. However, the said provisions are applicable where the gross receipts paid or payable does not exceed Rs. 40 lakhs. iii. The Hon'ble ITAT, Kolkata Bench in the case

BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. ITO, WARD - 10(1), , KOLKATA

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

43C of the Act. This income is to be deemed to be the profits and gains of said business chargeable of tax under the head "profits and gains" of business. However, the said provisions are applicable where the gross receipts paid or payable does not exceed Rs. 40 lakhs. iii. The Hon'ble ITAT, Kolkata Bench in the case

THE TIMKEN COMPANY,KOLKATA vs. THE DDIT, INTERNATIONAL TAXATION - 3(1),KOLKATA, KOLKATA

In the result appeals for AY 2004-05 to 2007-08 are allowed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

Section 9(1)(vii) Explanation 2, stops with the ‘rendering’ of technical services. The DTAA goes further and qualifies such rendering of services with words to the effect that the services should also make available technical knowledge, experience, skill etc. to the person utilizing the services. The meaning of the expression make available were considered by the Tribunal

THE TIMKEN COMPANY,KOLKATA vs. A.D.I.T (INTERNATIONAL TAXATION) - II,KOLKATA, KOLKATA

In the result appeals for AY 2004-05 to 2007-08 are allowed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

Section 9(1)(vii) Explanation 2, stops with the ‘rendering’ of technical services. The DTAA goes further and qualifies such rendering of services with words to the effect that the services should also make available technical knowledge, experience, skill etc. to the person utilizing the services. The meaning of the expression make available were considered by the Tribunal

ADIT(IT)-3(1), KOLKATA, KOLKATA vs. THE TIMKEN COMPANY, KOLKATA

In the result appeals for AY 2004-05 to 2007-08 are allowed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

Section 9(1)(vii) Explanation 2, stops with the ‘rendering’ of technical services. The DTAA goes further and qualifies such rendering of services with words to the effect that the services should also make available technical knowledge, experience, skill etc. to the person utilizing the services. The meaning of the expression make available were considered by the Tribunal