DZ BANK INDIA REPRESENTATIVE OFFICE,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Dz Bank, India Representative Dcit (International Taxation) Office C/O Srbc & Associates Llp, Range-2(1)(2), 14Th Floor, The Ruby, 29, Senapati Vs. 16Th Floor, Room No. 1612, Air Bapat Marg, Dadar (West), India Building, Nariman Point, Mumbai-400028. Mumbai-400021. Pan No. Aabcd 6455 E Appellant Respondent

TDS certificate issued under Section 203 Section 203 of the Act. Section 205 Section 205 of the Act provides that where tax is of the Act provides that where tax is deductible at the source under Chapter XVII of the Act, the deductible at the source under Chapter XVII of the Act, the deductible at the source under Chapter XVII

DZ BANK INDIA REPRESENTATIVE OFFICE,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, all the four appeals of the assessee to the extent of In the result, all the four appeals of the assessee to the extent of the recalled grounds, are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2014-15 Dz Bank, India Representative Dcit (International Taxation) Office C/O Srbc & Associates Llp, Range-2(1)(2), 14Th Floor, The Ruby, 29, Senapati Vs. 16Th Floor, Room No. 1612, Air Bapat Marg, Dadar (West), India Building, Nariman Point, Mumbai-400028. Mumbai-400021. Pan No. Aabcd 6455 E Appellant Respondent

TDS certificate issued under Section 203 Section 203 of the Act. Section 205 Section 205 of the Act provides that where tax is of the Act provides that where tax is deductible at the source under Chapter XVII of the Act, the deductible at the source under Chapter XVII of the Act, the deductible at the source under Chapter XVII

ANIL KUMAR GANG,JODHPUR vs. ITO 3(1) JODHPUR, JODHPUR

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

TDS certificate issued under section 203 of the Act. Section 205 of the Act provides that where tax is deductible at the source under Chapter XVII of the Act, the assessee shall not be called upon to pay the tax himself to the extent to which tax has been deducted. 19. Section 205 of the Act as it stood

BOARD OF CONTROL FOR CRICKET IN INDIA,MUMBAI vs. DCIT CENT. CIR. 6(2), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

TDS under section 194E of the Act. The learned DR submitted that the agreement entered into with CSA in 2008 was to continue

BOARD OF CONTROL FOR CRICKET IN INDIA,MUMBAI vs. DCIT CENT. CIR. 6(2), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

TDS under section 194E of the Act. The learned DR submitted that the agreement entered into with CSA in 2008 was to continue

REKHA MAHESHWARI ,DELHI vs. INCOME TAX OFFICER , DELHI

In the result, appeal of the assessee is allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

194E, respectively. 8.3 As far as payments made to non-residents [not being a company], or to a foreign company are concerned, any interest (not being interest referred to in section 194LB or section 194LC or section 194LD) or any other sum chargeable under the provisions of this Act (not being income chargeable under the head "Salaries" ) payable to such

SHARANGPANI DINKAR PANT,MUMBAI vs. INTERNATIONAL TAX WARD 3(3)(1) , MUMBAI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopalassessment Year: 2018-19 & Assessment Year: 2018-19 Shri Sharangpani Dinkar Ito It 3(3)(1), Pant, International Tax Ward- 402, Bhoomi Oscar, 3(3)(1), Plot No.16/17, Vs. Air India Building, Sector-9, Mumbai – 400 021 Ghansoli, Navi Mumbai - 400 701 Pan: Aippp0288E (Appellant) (Respondent) Present For: Assessee By : Shri Balaji V, A.R. Revenue By : Shri Anil Sant, D.R. Date Of Hearing : 13 . 02 . 2024 Date Of Pronouncement : 26 . 02 . 2024 O R D E R Per : Amarjit Singh: Both These Appeals Are Filed By The Assessee For The Same Assessment Year I.E. 2018-19 Against The Two Different Orders Of The Ld. Cit(A) Passed Under Section 250 Of The Act On The Common Issue Of Allowability Of Tds Credit Of Rs.17,59,258/- Which Was Not Allowed By The Ao Vide Order Passed Under Section 154 Of The Act & Under Section 143(1) Of The Act. The Assessee Vide Ita

TDS is not in accordance with the decision of the Hon'b1e Supreme Court in the case of PILCOM v CIT 425 ITR 312 (SC) wherein the Hon'ble Apex Court has held that the obligation to deduct tax under Section is 194E

SHARANGPANI DINKAR PANT,MUMBAI vs. ITO WARD 3(3)(1), MUMBAI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopalassessment Year: 2018-19 & Assessment Year: 2018-19 Shri Sharangpani Dinkar Ito It 3(3)(1), Pant, International Tax Ward- 402, Bhoomi Oscar, 3(3)(1), Plot No.16/17, Vs. Air India Building, Sector-9, Mumbai – 400 021 Ghansoli, Navi Mumbai - 400 701 Pan: Aippp0288E (Appellant) (Respondent) Present For: Assessee By : Shri Balaji V, A.R. Revenue By : Shri Anil Sant, D.R. Date Of Hearing : 13 . 02 . 2024 Date Of Pronouncement : 26 . 02 . 2024 O R D E R Per : Amarjit Singh: Both These Appeals Are Filed By The Assessee For The Same Assessment Year I.E. 2018-19 Against The Two Different Orders Of The Ld. Cit(A) Passed Under Section 250 Of The Act On The Common Issue Of Allowability Of Tds Credit Of Rs.17,59,258/- Which Was Not Allowed By The Ao Vide Order Passed Under Section 154 Of The Act & Under Section 143(1) Of The Act. The Assessee Vide Ita

TDS is not in accordance with the decision of the Hon'b1e Supreme Court in the case of PILCOM v CIT 425 ITR 312 (SC) wherein the Hon'ble Apex Court has held that the obligation to deduct tax under Section is 194E

BLUE FROG MEDIA P. LTD,MUMBAI vs. DCIT CIR 5(3), MUMBAI

In the result, appeals of the assessee are partly allowed for statistical purposes

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Ble

TDS. Coming to the charges paid to Non-resident Artists the Ld.CIT(A) taking note of the amendment to Section 194E

BLUE FROG MEDIA P. LTD,MUMBAI vs. DCIT CIR 5(3), MUMBAI

In the result, appeals of the assessee are partly allowed for statistical purposes

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Ble

TDS. Coming to the charges paid to Non-resident Artists the Ld.CIT(A) taking note of the amendment to Section 194E

LLOYDS REGISTER ASIA (INDIA BRANCH OFFICE,MUMBAI vs. DCIT (IT) 3(1)(2), MUMBAI

In the result, appeals are allowed in term of the above

Bench: Sri Mahavir Singh, Vp & Sri Manoj Kumar Aggarwal, Am आमकय अऩीर िं./ Ita No. 985/Mum/2015 (ननधाायण वर्ा / Assessment Year 2010-11) आमकय अऩीर िं./ Ita No. 1918/Mum/2016 (ननधाायण वर्ा / Assessment Year 2011-12) आमकय अऩीर िं./ Ita(Tp) No. 1076/Mum/2017 (ननधाायण वर्ा / Assessment Year 2012-13) आमकय अऩीर िं./ Ita No. 7423/Mum/2017 (ननधाायण वर्ा / Assessment Year 2013-14) आमकय अऩीर िं./ Ita No. 6310/Mum/2018 (ननधाायण वर्ा / Assessment Year 2014-15) आमकय अऩीर िं./ Ita No. 7775/Mum/2019 (ननधाायण वर्ा / Assessment Year 2015-16) Lloyd’S Register Asia (India Dy. Commissioner Of Branch Office) Income-Tax (International 63-64, Kalpatru Square, 6 Th Floor, Taxation)- 3(1)(2), Mumbai फनाभ/ Kondivita Lane, Off. Andheri Kurla Road, Andheri (E), Vs. Mumbai-400 059 (अऩीराथी / Appellant) (प्रत्मथी/ Respondent) स्थामी रेखा िं./Pan No. Aaacl9741J Lloyd’S Register Asia Ays 10-11 To 15-16 अऩीराथी की ओय े/ Appellant By : Shri Nitesh Joshi, Ar प्रत्मथी की ओय े/ Respondent By : Shri Sanjay Singh, Cit Dr ुनवाई की तायीख / Date Of Hearing: 02.07.2021 घोर्णा की तायीख / Date Of Pronouncement: 30.09.2021

TDS has been deducted on the same, as according to it, the said amount is not chargeable to tax under the Act. The said amount has been assessed in the hands of LRS in an assessment Order passed under section 143(3) of the Act and their appeal is presently pending before the CIT(A) pursuant to set aside

DEPUTY COMMISSIONER OF INCOME TAX(IT)-3(1)(2), MUMBAI, MUMBAI vs. LLOYDS REGISTER ASIA, MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

194E of the Act where liability to deduct tax was unconditional when the condition relating to nature of payment was fulfilled. In the present case before us, we are concerned with deduction of tax at source under section 195 of the Act where the obligation arises only when the sum is chargeable to tax under the Act. For ascertaining chargeability

DEPUTY COMMISSIONER OF INCOME TAX(IT)-3(1)(2), MUMBAI, MUMBAI vs. LLOYDS REGISTER OF SHIPPING, MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

194E of the Act where liability to deduct tax was unconditional when the condition relating to nature of payment was fulfilled. In the present case before us, we are concerned with deduction of tax at source under section 195 of the Act where the obligation arises only when the sum is chargeable to tax under the Act. For ascertaining chargeability

LLOYD'S REGISTER ASIA (INDIA BRANCH OFFICE),MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-3(1)(2), MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

194E of the Act where liability to deduct tax was unconditional when the condition relating to nature of payment was fulfilled. In the present case before us, we are concerned with deduction of tax at source under section 195 of the Act where the obligation arises only when the sum is chargeable to tax under the Act. For ascertaining chargeability

EMERGING MARKETS EQUITY INDEX MASTER FUND,MUMBAI vs. DCIT (INTERNATIONAL TAXATION)- 2(2)(1), MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

194E of the Act where liability to deduct tax was unconditional when the condition relating to nature of payment was fulfilled. In the present case before us, we are concerned with deduction of tax at source under section 195 of the Act where the obligation arises only when the sum is chargeable to tax under the Act. For ascertaining chargeability

LIOYD'S REGISTER ASIA (INDIA BRANCH OFFICE),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION -3(1)(2) , MUMBAI

In the result, all these appeals filed by the assessee are allowed for statistical

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Renu Jauhri, Am

194E of the Act where liability to deduct tax was unconditional when the condition relating to nature of payment was fulfilled. In the present case before us, we are concerned with deduction of tax at source under section 195 of the Act where the obligation arises only when the sum is chargeable to tax under the Act. For ascertaining chargeability

TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ACIT LARGE TAX PAYER UNIT-1, MUMBAI

797/Mum/2018

194E of the Act belongs to a set of various provisions which deal with tax deduction at source, without any reference to chargeability to tax under the Act of the non-resident assessee. This section is similar to sections 193 and 194 of the Act by which deductions have to be made without any reference to the chargeability

TATA CONSULTANCY SERRVICES LIMITED,MUMBAI vs. DCIT-1, MUMBAI

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

194E of the Act belongs to a set of various provisions which deal 33 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd with tax deduction at source, without any reference to chargeability to tax under the Act of the non-resident assessee. This section is similar to sections 193 and 194 of the Act by which deductions have to be made