July 2015

Section 9

AAR : The payments received by SkillSoft Ireland Limited (“the Applicant”) would be characterized as ‘fees for technical services’ (“FTS”) under Article 12(3)(b) of the Agreement between the Government of the Republic of India and the Government of Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income(“India-Ireland Treaty”)

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Authority For Advance Rulings (Income-Tax), New Delhi SkillSoft Ireland Ltd., In re Section 9 Justice V. S. Sirpurkar, Chairman And

Income Tax Case Laws, Sec. 260A, Section 263, Section 45, Section 48

Karnataka H.C : Whether the Tribunal was correct in proceeding to decide the matter on merits when the assessment order, subject matter of the appeal was set-aside by the Commissioner of Income Tax under Section 263 of the Act with a direction to the Assessing Officer to redo the same and consequently the appeal before the Tribunal has become infructuous

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High Court Of Karnataka CIT vs. Khivraj Motors Section 260A, 263, 45, 48 Vineet Saran & Aravind Kumar, JJ ITA

Income Tax Case Laws, Section 69A

Bombay H.C : The Tribunal was right in law in confirming the addition of Rs.2,01,200/- under section 69A of the Act in the Assessment Year 1987-88 when the assessee was not found to be owners of jewellery valued at the said amount in the financial year 1986-88 being the relevant previous year for the Assessment Year 1987-88 which is the requirement of section 69A of the Act

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High Court Of Bombay Ajay R. Dhoot vs. DCIT, Mumbai Section :69A Assessment year : 1987-88 M.S. Sanklecha And N.M.

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