COMMR.OF INCOME TAX,NEW DELHI vs. M/S ELI LILLY & COMPANY (INDIA) P.LTD

dividends, interest on securities etc. but the said provisions also apply to gross sums, the whole of which may not be income or profits in the hands of the recipient, such as payment to contractors and sub-contractors. The purpose of TDS provisions in Chapter XVII B is to see that the sum which is chargeable under Section

COMMISSIONER OF INCOME TAX CHENNAI vs. TULSYAN NEC LTD

dividends paid or proposed; or (f) the amount or amounts of expenditure relatable to any income to which any of the provisions of Chapter III applies; if any amount referred to in clauses (a) to (f) is debited to the profit and loss account, and as reduced by,— (i) the amount withdrawn from any reserves or provisions if any such

MALAYALA MANORAMA CO LTD. vs. COMMR.OF INCOME TAX, TRIVANDRUM

The appeals are allowed and the

dividend to provide for depreciation for the relevant accounting year. Further, the company is required under section 205 to set off against the profit of the relevant accounting year, the depreciation debited to the profit and loss account of any earlier year(s) or loss whichever is less. 36.3 Section 115J, therefore, involves two processes. Firstly, an assessing authority

NATIONAL PETROLEUM CONSTRUCTION COMPANY vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(2) INTERNATIONAL TAXATION NEW DELHI

Appeal is hereby allowed to the extent

Bench: HON'BLE MS. JUSTICE INDIRA BANERJEE

deemed to be received   by   him   in   India.   The   aforesaid   provision   has   been brought with an intent to check the double taxation. Thus, from above for clarity, it is reiterated that any income outside India to a non­resident would not be taxable in India even if it is specified in the balance sheet prepared in India. 7. By a judgment

THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

TDS Officer and the AAR had expressed only a prima facie view of the matter. The order dated 17.08.2018 passed under Section 197 of the Act merely prescribed a tentative and provisional rate of deduction of tax at source and did not amount to a conclusive determination of tax liability. Likewise, the AAR while observing that the transaction appeared prima