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Section 254(2)4 Double Taxation/DTAA3 TDS3 Permanent Establishment2

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

Appeal is hereby allowed to the extent

C.A. No.-004964-004964 - 2022Supreme Court29 Jul 2022

Bench: HON'BLE MS. JUSTICE INDIRA BANERJEE

Section 143(1)Section 197

Permanent Establishment’ (PE) and that the Appellant’s Project Office constituted a PE of the Appellant in India. The DRP concurred with the AO that ASL was a DAPE of the Assessee. 14. The DRP observed that pre-engineering or pre- design survey, claimed to be done by a sub-contractor employed by the Appellant, was an integral part

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-008733-008734 - 2018Supreme Court02 Mar 2021

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

permanent establishment [“PE”] in India. 19 16. Shri S. Ganesh, learned Senior Advocate appearing on behalf of Sonata Information Technology Ltd. in C.A. Nos. 8737-8941/2018, submitted that to comprehend the nature of a licence, one would have to refer to section 52 of the Indian Easements Act 1882. He stressed the fact that the ruling

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

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

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

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

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

COMMISSIONER OF INCOME TAX (IT)4 vs. M/S. RELIANCE TELECOM LTD

COMMISSIONER OF INCOME TAX (TDS), KANPUR vs. CANARA BANK