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Rulings

Jun 06,2018

Delhi ITAT Special Bench (majority view) rules in favour of Nokia Networks OY (assessee, a Finnish company), holds Nokia India Pvt. Ltd. (NIPL, Indian subsidiary) does not constitute assessee’s PE

Jun 06,2018

Mumbai ITAT holds that Executive Search Services fees (‘ESF’) received by assessee (a Dutch company) not taxable as FTS under Article 12 of India-Netherlands DTAA for AY 2011-12; Rejects Revenue's

Jun 05,2018

Mumbai ITAT rejects applicability of TDS u/s 195 on payment of advertisement expenses and professional and consultancy fees paid to foreign nationals by the UK branch of assessee (a domestic

Jun 05,2018

Delhi ITAT rejects AO’s attribution of 50% profits made by Corning SAS in France (AE), from direct sales made in India, to its India Branch office (BO) for AY 2005-06;

Jun 04,2018

Mumbai ITAT deletes over Rs. 3,200 cr. capital gains addition made by AO invoking Explanation 5 to Sec. 9(1) [relating to indirect transfers] in case of resident company (‘assessee’) during

Jun 04,2018

AAR rules that the Liaison office (‘LO’) of the Applicant (International Zinc Association, a Belgium based International Non-Profit Association) established in India for conducting programmes / conferences / training on importance of zinc, not

Jun 04,2018

AAR rules that Indian hotel managed and operated by Applicant (a Luxembourg based group engaged in operation and management of the hotels) would constitute its fixed place PE in India

Jun 01,2018

Cochin ITAT rejects assessee’s (a software company) stand that payment to its sister concern (‘USTIPL’) under the sub-contracting agreement amounts to reimbursement of expenses, upholds applicability of TDS u/s 194J; Perusing agreement

May 31,2018

Jaipur ITAT deletes disallowance u/s 40A(3) with respect to cash payment made by assessee-firm (engaged in real estate business) against purchases of land during AY 2013-14, observes that the payment was

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