Sec. 245Q, Sec. 9(1)(vi)

AAR : Payments received by the Applicant from the Indian hotel owner for provision of global reservation services (‘GRS’) would be chargeable to tax in India as ‘Fees for Technical Services’or ‘Royalty’under the provisions of section 9(1)(vi) / 9(1)(vii) of the Income tax Act, 1961 (“the Act”) read with provisions of Article 12 of the Double Taxation Avoidance Agreement between India and Luxembourg

Authority Of Advance Rulings FRS Hotel Group (Lux) S.A.R.L. In Re Section 245Q(1), 9(1)(vi), 10.2 R.S. Shukla, In-Charge Chairman & […]

Sec. 245Q, Sec. 2(24), Sec. 2(24)(iii), Sec. 28(iii)

AAR : The representative/liaison office (LO) proposed to be established by IZA in India would be liable to income-tax in India under the provisions of the Act or the provisions of Double Taxation Avoidance agreement between India and Belgium (‘India -Belgium DTAA’’)

Authority Of Advance Rulings International Zinc Association In Re Section 245Q(1), 28(iii), 2(24)(iii) R.S. Shukla, In-Chargechairman & Ashutosh Chandra, Member

Income Tax Case Laws, Sec. 194A, Sec. 201(1A), Section 145, Section 201

Punjab & Haryana H.C : The payment @ 12% per annum of the amount of compensation paid and recorded as interest in the “Award of Compensation” of the Punjab Government is enhanced/additional compensation ignoring the facts that initial notification was published on 22.4.2010 and competent authority/DFCCIL-cum-district Revenue Officer announced award on 27.2.2012. Thus payment @ 12% has been given for delay in payment which is clearly in the nature of interest

High Court Of Punjab & Haryana CIT (TDS) vs. Dedicated Freight Corridor Corporation Limited Section 145A, 194A, 201(1A) and Section

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