PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

239) ITR 879 (AAR). 37. Mr. Bhatia also refuted Mr. Jolly‟s submission with respect to attribution and argued that the margin of 35% was correct and reasonable. Analysis and Conclusions: 38. The relevant provision of the DTAA, i.e the Indo-US DTAA reads as follows: “Article 5.1. For the purposes of this Convention, the term „permanent establishment' means

Commissioner of Income Tax vs. Sri P.Sarveswara Rao

Appeals are partly allowed, in view of the

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

gains under Case I of Schedule D. It is sufficient to cite the decision of this House in the sugar beet case (Smart v. Lincolnshire Sugar Co. Ltd. [1937] 20 TC 643; 156 LT 25] as an illustration. The second proposition constitutes an exception. If the undertaker is a rating authority and the subsidy is the proceeds of rates imposed

M/s. Canara Securities Ltd vs. Dy. Commissioner of Income Tax

Bench: M.S.RAMACHANDRA RAO,T.AMARNATH GOUD

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became