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

TDS provisions in respect of the amount it pays. Therefore, according to the learned counsel, the said sub-section belies the concept of aggregation or consolidation of the entire amount under the head “salaries” being exigible to deduction of tax at source under Section 192 in the hands of one person responsible for paying a part thereof. Lastly, learned counsel

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

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

Bench: HON'BLE MR. JUSTICE M.R. SHAH

195(2) of the Act before the Assessing Officer, to make payment to the non- resident company for purchase of software without TDS. It was contended by the Assessee that it was for the purchase of software and Ericsson A.B. had no permanent establishment in India and in terms of the DTAA between India and Sweden & USA, the amount paid