NARAYAN CHANDRA JANA,PURBA MEDINIPUR vs. ITO, WARD - 27(3), HALDIA, HALDIA

In the result, the appeal of assessee allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

68 or u/s. 69 of the Act. Considering these facts and circumstances and in the light of aforesaid decisions, we are inclined to set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Therefore, this ground of appeal of the assessee is allowed. 6. The issue raised in ground no. 2 is against

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]

68,47,415 Contract receipts 87,45,69,722 (sales) Purchases [ work allotted 79,61,15,855 Commission and other 11,17,53,928 to sub contractors back to receipts back] Fright, Power & Fuel and 14,49,03093 Other income 7,76,96,586 Salary & Wages Other expenses against 7,30,20,695 Closing Stock 4,16,85,144 other

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]

68,47,415 Contract receipts 87,45,69,722 (sales) Purchases [ work allotted 79,61,15,855 Commission and other 11,17,53,928 to sub contractors back to receipts back] Fright, Power & Fuel and 14,49,03093 Other income 7,76,96,586 Salary & Wages Other expenses against 7,30,20,695 Closing Stock 4,16,85,144 other

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]

68,47,415 Contract receipts 87,45,69,722 (sales) Purchases [ work allotted 79,61,15,855 Commission and other 11,17,53,928 to sub contractors back to receipts back] Fright, Power & Fuel and 14,49,03093 Other income 7,76,96,586 Salary & Wages Other expenses against 7,30,20,695 Closing Stock 4,16,85,144 other

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]

68,47,415 Contract receipts 87,45,69,722 (sales) Purchases [ work allotted 79,61,15,855 Commission and other 11,17,53,928 to sub contractors back to receipts back] Fright, Power & Fuel and 14,49,03093 Other income 7,76,96,586 Salary & Wages Other expenses against 7,30,20,695 Closing Stock 4,16,85,144 other

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]

68,47,415 Contract receipts 87,45,69,722 (sales) Purchases [ work allotted 79,61,15,855 Commission and other 11,17,53,928 to sub contractors back to receipts back] Fright, Power & Fuel and 14,49,03093 Other income 7,76,96,586 Salary & Wages Other expenses against 7,30,20,695 Closing Stock 4,16,85,144 other

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

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

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