Commissioner Of Income Tax International Taxation 3 vs. Samsung Heavy Industries Company Limited
Appeal stands dismissed
ITA/10/2024HC Uttarakhand10 Jul 2025
Bench: HON'BLE MR JUSTICE G. NARENDAR,HON'BLE MR. JUSTICE ALOK MAHRA
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 194CSection 194JSection 260Section 40
3
2025:UHC:5945-DB
payments to Arjun Engineering Pvt. Ltd. and
Builcraft Interior Pvt. Ltd and deduced tax at
source @2% thereon in terms of section
194C of the Act for carrying out electrification
work and interior work respectively. The
revenue concluded that the said work falls
under the limb of professional services and
fee
for
technical
services
warranting
