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11 results for “TDS”+ Section 9(1)(vi)clear

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Key Topics

Section 115J6TDS6Section 194A5Section 276C5Section 804Section 254(2)4Section 133A3Double Taxation/DTAA3Survey u/s 133A3Section 143(1)

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

C.A. No.-005114-005114 - 2007Supreme Court25 Mar 2009
Section 133ASection 192(1)Section 201(1)Section 9(1)(ii)

9(1)(ii). As stated above, the post-survey operations revealed that no work stood performed for the foreign company by the four expatriates to the joint venture company in India and that the total remuneration paid was only for services rendered in India. In such a case the tax-deductor-assessee was statutorily obliged to deduct tax under Section

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

section 9(1)(vi) of the Income Tax Act, 1961 [“Income Tax Act”], thereby making it incumbent upon all such persons to deduct tax at source and pay such tax deductible at source [“TDS

2
Section 201(1)2
Permanent Establishment2

VINUBHAI MOHANLAL DOBARIA vs. CHIEF COMMISSIONER OF INCOME TAX

The appeal is disposed of in the aforesaid terms

C.A. No.-001977-001977 - 2025Supreme Court07 Feb 2025

Bench: HON'BLE MR. JUSTICE J.B. PARDIWALA

Section 143(1)Section 276C

vi. Offences committed by a person for which he was convicted by a court of law under Direct Taxes laws. vii. Offences committed by a person for which complaint was filed with the competent court 12 months prior to receipt of the application for compounding. viii. Offences committed by a person whose application for 'plea-bargaining' under Chapter

COMMISSIONER OF INCOME TAX CHENNAI vs. TULSYAN NEC LTD

C.A. No.-010677-010679 - 2010Supreme Court16 Dec 2010
Section 115J

VI-A 80G-Donation 80HHC-profits 80-1A new industrial unit 1,500,000 6,590,600 11,322,409 1,500,000 6,590,600 11,322,409 Net Income 234,868,455 234,868,455 Tax payable Surcharge on the above at 13% 68,586,949 8,916,303 68,586,950 8,916,304 Total

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

The appeals are allowed and the

C.A. No.-005420-005423 - 2002Supreme Court10 Apr 2008
For Respondent: Commissioner of Income Tax,Trivandrum
Section 115JSection 33Section 80Section 80V

9 of 12 is authorised by the definition given in Explanation to Section 115J of the Income- tax Act, if the accounts are prepared and certified to be in accordance with Parts II and III of Schedule VI to the Companies Act, 1956. In the case of Apollo Tyres Ltd. [2002] 255 JTR 273, the apex court held that while

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

C.A. No.-000262-000262 - 2026Supreme Court15 Jan 2026

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

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

9. But for the purpose of tax deduction at source at lower rate or no deduction during contractual period, the assessing officer has been empowered under Section 197(1) to issue a certificate   to   that   effect   in   the   manner   so   prescribed   as 27 specified in Chapter XVII of Income Tax Act which relates to collection and recovery

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

C.A. No.-006820-006820 - 2005Supreme Court10 Aug 2007
For Respondent: M/s. Century Building Industries Pvt. Ltd
Section 133ASection 194ASection 194A(1)Section 201Section 201(1)

vi) to such income credited or paid in respect of deposits under any scheme framed by the Central Government and notified by it in this behalf in the Official Gazette; (vii) to such income credited or paid in respect of deposits (other than time deposits made on or after the 1st day of July, 1995) with a banking company

COMMR.OF INCOME TAX,BANGALORE vs. M/S INFOSYS TECHNOLOGIES LTD

C.A. No.-003725-003725 - 2007Supreme Court04 Jan 2008
For Respondent: Infosys Technologies Ltd
Section 17(2)(iii)Section 192

TDS under Section 192 amounting to Rs. 49.52 crores on the above perquisite value of Rs. 165 crores. Similar orders were also passed by the AO for assessment years 1997-98 and 1998-99. These orders were confirmed by CIT(A). No http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 2 of 6 weightage was given by both the authorities

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

C.A. No.-007110-007110 - 2021Supreme Court03 Dec 2021

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

Section 195(2)Section 254(2)Section 9(1)(vi)

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 is not taxable in India. 2 2.2 The Assessing Officer passed an order dated 12.03.2007 rejecting the Assessee’s application holding that

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

The appeals are dismissed

C.A. No.-006020-006020 - 2018Supreme Court02 Jul 2018

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

Section 194ASection 3

TDS),   Kanpur   and   Anr.   vs. Canara   Bank   wherein   the   judgment   of   the   High   Court   dated 04.04.2016 in ITA No. 64 of 2016 has been questioned. 4 3.   The New Okhla Industrial Development Authority  (NOIDA), hereinafter referred to as “Authority” has been constituted by Notification dated 17.04.1976 issued under Section 3 of the Uttar   Pradesh   Industrial   Area   Development   Act,   1976 hereinafter