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

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

TDS, without any reference to chargeability of tax under the Income Tax Act by the concerned non- resident assessee. This section is similar to sections 193 and 194 of the Income Tax Act by which deductions have to be made without any reference to the chargeability of a sum received by a non-resident assessee under the Income

SHREE CHOUDHARY TRANSPORT CO. vs. INCOME TAX OFFICER

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

III to section 194C; *** *** ***”12 13.3. Section 43 in the very same Part D of Chapter IV of the Act of 1961 defines various terms relevant to the income from profits and gains of business or profession; and clause (2) thereof, carrying the definition of the expression “paid”, having been referred in the present matter, could also be usefully reproduced

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

36. It is well settled that the obligation to deduct TDS is limited to appropriate proportion of income chargeable to tax under the IT Act that forms part of the gross sum of money payable to the non-resident. A person paying any sum to a non-resident is not liable to deduct any tax at source if such

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

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

36,473.83 3. Tiger Global International IV Holdings, Mauritius 66,026 USD 8,435,171.44 equivalent to INR Rs.58,45,57,380.79 5.6. Thereafter, the assessees approached the Indian tax authorities by filing applications under Section 197 of the Income Tax Act, 19619, seeking certification of nil withholding prior to consummation of the transfer. By notices dated

COMMNR. OF INCOME TAX, BANGALORE vs. M/S. CENTURY BUILDING INDUSTRIES PVT.LTD

36 [***], [* * *] the aforesaid amount shall be computed with reference to the income credited or paid by a branch of the banking company or the co- http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 4 of 5 operative society or the public company, as the case may be;] (ii) [***] (iii) to such income credited or paid to- (a) any banking company

NEW OKHLA INDUSTRIAL DEVELOPMENT AUTHORITY vs. CHIEF COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE ASHOK BHUSHAN

TDS), Kanpur vs. Canara Bank where we have considered and decided those issues by our judgment of this date. After dismissal of the writ petition dated 28.02.2011 the appellant filed a review application which too was dismissed on 04.11.2011. Aggrieved by those two judgments Civil Appeal Nos.792-793 of 2014 have been filed by the appellant. 6. We have heard Shri

THE DIR. PRASAR BHARATI vs. COMMISSIONER OF INCOME TAX, THIRUVANANTH

Bench: HON'BLE MR. JUSTICE ABHAY MANOHAR SAPRE

1-A) of the Act. 14. The appellant felt aggrieved and filed appeals before the Commissioner of Income Tax (Appeals)-II, Thiruvanathapuram. By order dated 04.03.2005, the Commissioner concurred with the reasoning and conclusion arrived at by AO and accordingly dismissed the appeals. 15. The appellant felt aggrieved and filed appeals before the Tribunal. By order dated 28.03.2007, the Tribunal

HONDA SIEL CARS INDIA LTD vs. COMMISSIONER OF INCOME TAX, GHAZIABAD

In the results. As a consequence, we find no

Bench: HON'BLE MR. JUSTICE A.K. SIKRI

36 crores shares out of which 35,63,99,995 shares were held by HMCL, Japan while remaining 3600005 shares held by M/s. Seil India. In other words, joint venture was almost owned by HMCL, Japan, having around 99% shares and Seil India (local Indian Civil Appeal No. 4918 of 2017 & Ors. Page 4 of 34 company) owned only 1