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10 results for “TDS”+ Section 115Aclear

Sorted by relevance

Delhi132Mumbai93Bangalore45Dehradun28Kolkata13Chennai10Pune10Chandigarh7Ahmedabad2SC1Jaipur1Karnataka1

Key Topics

Section 201(1)18Section 20116Section 19512Section 99TDS8Section 115A7Section 9(1)(vi)7Double Taxation/DTAA7Section 144C(1)4Section 143(3)

DEPUTY COMMISSIONER OF INCOME-TAX vs. MAGNA INTERNATIONAL INC.,, PUNE

In the result, appeal of Revenue and Cross Objections of assessee are allowed

ITA 2098/PUN/2016[2013-14]Status: DisposedITAT Pune21 Jan 2019AY 2013-14

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.2098/Pun/2016 यििाारण वषा / Assessment Year : 2013-14

For Appellant: S/Shri Kishore Phadke & Vinay Ghanekar
Section 115ASection 115A(1)Section 143(3)Section 144C(1)

section 115A of the Act 6 CO No.54/PUN/2018 Magna International Inc. at 10% (plus surcharge and cess), which was applicable for the year under consideration. The assessee during the course of assessment proceedings discovered that sum of ₹ 62,12,060/- was inadvertently not offered to tax in the income tax return so filed. TDS

3

GRI RENEWABLE INDUSTRIES S L (FORMERLY KNOWN AS GONVARRI EOLICA S L),MADRID vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE -1, PUNE

In the result, the appeal is partly allowed

ITA 202/PUN/2021[2016-17]Status: DisposedITAT Pune15 Feb 2022AY 2016-17

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.202/Pun/2021 "नधा"रण वष" / Assessment Year : 2016-17

Section 115ASection 143(3)Section 90Section 90(1)

section 90(1) of the Act leaving no room for any separate notification for the importation. The sequitur is that that the authorities below were not justified in denying the benefit of the straight rate of tax at 10% as per the DTAA read with Portuguese DTAA and also additionally charging Surcharge and Education cess. 14 GRI Renewable Industries

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 906/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

115A(1A) of the Act was on the Statute and the said section already was there, so definition of ‘royalty’ was covered. The amendment brought in to section 9(1)(vi) of the Act was clarificatory in nature, for removal of doubts and cannot be said to be prospective application. He then pointed out that if it is literary work

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 907/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

115A(1A) of the Act was on the Statute and the said section already was there, so definition of ‘royalty’ was covered. The amendment brought in to section 9(1)(vi) of the Act was clarificatory in nature, for removal of doubts and cannot be said to be prospective application. He then pointed out that if it is literary work

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 908/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

115A(1A) of the Act was on the Statute and the said section already was there, so definition of ‘royalty’ was covered. The amendment brought in to section 9(1)(vi) of the Act was clarificatory in nature, for removal of doubts and cannot be said to be prospective application. He then pointed out that if it is literary work

JOHN DEERE INDIA PVT. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

ITA 905/PUN/2015[2007-08]Status: DisposedITAT Pune23 Jan 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

115A(1A) of the Act was on the Statute and the said section already was there, so definition of ‘royalty’ was covered. The amendment brought in to section 9(1)(vi) of the Act was clarificatory in nature, for removal of doubts and cannot be said to be prospective application. He then pointed out that if it is literary work

M/S. TATA TECHNOLOGIES LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed

ITA 1433/PUN/2014[2007-08]Status: DisposedITAT Pune05 Apr 2018AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune

For Appellant: S/Shri Dhanesh Bafna and Arpitha ChoudaryFor Respondent: S/Shri Vivek Aggarwal and Mukesh Jha
Section 115ASection 195Section 201Section 201(1)Section 9(1)(vi)Section 90(2)

115A of the Act in respect of payment to Greece entities instead of the applicable beneficial tax rate 10% (plus applicable surcharge and cess) under the Act in the tax demand computation in the order passed under section 201(1) read with section 201(1A).” 5. The ground of appeal No.7 is not pressed and hence, the same is dismissed

INDIA SOFT TECHNOLOGIES PVT. LTD.,,PUNE vs. DDIT (INT. TAX.)-I,, PUNE

In the result, appeal of the assessee for A

ITA 1712/PUN/2013[2011-12]Status: DisposedITAT Pune24 Jan 2018AY 2011-12

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1709 To 1712/Pun/2013 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2008-09 To 2011-12 वष"

For Appellant: Shri M.K. KulkarniFor Respondent: Shri Achal Sharma, Addl. CIT
Section 195Section 201Section 5(2)Section 9

TDS on the said remittances to the suppliers at USA/UK. On examination of the said agreements with the said suppliers, AO came to the conclusion that assessee has got right to sub- lease the said products. For example, the clauses of the agreement dated 15-06-2006 of the assessee with Process System Enterprise, UK are cited. As per Para

INDIA SOFT TECHNOLOGIES PVT. LTD.,,PUNE vs. DDIT (INT. TAX.)-I,, PUNE

In the result, appeal of the assessee for A

ITA 1709/PUN/2013[2008-09]Status: DisposedITAT Pune24 Jan 2018AY 2008-09

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1709 To 1712/Pun/2013 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2008-09 To 2011-12 वष"

For Appellant: Shri M.K. KulkarniFor Respondent: Shri Achal Sharma, Addl. CIT
Section 195Section 201Section 5(2)Section 9

TDS on the said remittances to the suppliers at USA/UK. On examination of the said agreements with the said suppliers, AO came to the conclusion that assessee has got right to sub- lease the said products. For example, the clauses of the agreement dated 15-06-2006 of the assessee with Process System Enterprise, UK are cited. As per Para

INDIA SOFT TECHNOLOGIES PVT. LTD.,,PUNE vs. DDIT (INT. TAX.)-I,, PUNE

In the result, appeal of the assessee for A

ITA 1711/PUN/2013[2010-11]Status: DisposedITAT Pune24 Jan 2018AY 2010-11

Bench: Shri D.Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita Nos.1709 To 1712/Pun/2013 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Years : 2008-09 To 2011-12 वष"

For Appellant: Shri M.K. KulkarniFor Respondent: Shri Achal Sharma, Addl. CIT
Section 195Section 201Section 5(2)Section 9

TDS on the said remittances to the suppliers at USA/UK. On examination of the said agreements with the said suppliers, AO came to the conclusion that assessee has got right to sub- lease the said products. For example, the clauses of the agreement dated 15-06-2006 of the assessee with Process System Enterprise, UK are cited. As per Para