S.C : There would be no question of inviting the penalty under s. 271(1)(c)
Supreme Court Of India CIT vs. Reliance Petroproducts (P) Ltd. Section 271(1)(c) Asst. Year 2001-02 V.S. Sirpurkar & Dr. Mukundakam […]
Sec. 271(1)(c )
322 ITR
Section 9, Sec. 9(1)(vi), Section 195
AAR : Whether pursuant to the cost contribution agreement proposed to be entered by the applicant with ABB Research Ltd., Zurich (“ABB Zurich”), the payments to be made to ABB Zurich, representing the applicant’s share of the costs incurred towards basic research and development (“R&D”) activities, constitutes “income” in the hands of ABB Zurich within the meaning of the term in s. 2(24)
Authority For Advance Rulings ABB Ltd., IN RE Section 9(1)(vi), 195, DTAA between India & Switzerland, art. 7, DTAA between
Sec. 37(1), Section 43A
S.C : Whether on the facts and circumstances of the case, the additional liability arising on account of fluctuations in the rate of exchange in respect of loans taken for revenue purposes could be allowed as deduction under s. 37(1) of the IT, Act, 1961 (for short ‘the Act’) in the year of fluctuation in the rate of exchange or whether the same is allowable only in the year of repayment of such loans ?
Supreme Court Of India Oil & Natural Gas Corpn. Ltd. vs. CIT Section 37(1), 43A Asst. Year 1991-92, 1992-93, 1993-94,
Section 237, Section 240
Madras H.C : The assessee and the similarly placed employees have to seek help from the employer to get the refund along with interest.
High Court Of Madras Smt. Ramaa Sivaram vs. Chief Commissioner Of Income Tax & Anr. Section 237, 240 Mrs. Chitra
Section 5, Sec. 5(2), Sec. 9(1)(i), Section 9
AAR : Whether AramCo Overseas Company BV (‘applicant’) will be taxable in India, in respect of support services rendered by its Indian office for purchases made by the applicant and its group company, in light of the provisions of the IT Act, 1961
Authority For Advance Rulings Aramco Overseas Company Bv, In Re Section 5(2), 9(1)(i), Expln. 1(b) P.V. Reddi, J., Chairman; J.
Sec. 9(1)(Vii), Sec. 44BB, Sec. 44DA
AAR : Whether on the stated facts and in law the income derived by Master & Commander AS (M&C) ought to be computed in accordance with the computational mechanism under s. 44BB of the Act ?
Authority For Advance Rulings Wavefield Inseis Asa, In Re Section 9(1)(vii), 44BB, 44DA, 115A P.V. Reddi, J., Chairman; J. Khosla,
Section 90
AAR : Whether the payments received by the applicant for the proposed recruitment services and referral services from the Indian clients is liable to tax withholding under s. 195 of the IT Act, 1961 read with DTAA between India and UK ?
Authority For Advance Rulings Real Resourcing Ltd., In Re Section 90, DTAA between India & UK, art. 5, DTAA between
Sec. 36(1)(iii), Sec. 37(1), Section 43A
S.C : The assessee filed an appeal(s) before the Gujarat High Court inter alia challenging the capitalization of the roll over charges paid in respect of foreign currency
Supreme Court Of India Assistant Commissioner Of Income Tax vs. Elecon Engineering Co. Ltd. Section 36(1)(iii), 37(1), 43A Asst. Year
Section 90
AAR : Whether the applicant in the stated facts and circumstances, would have a PE in India under art. 5(1) or 5(8) of the India-Singapore Double Taxation Avoidance Agreement (“India-Singapore DTAA” or “treaty”) in relation to the activity of delivering goods through a customs bonded warehouse owned and operated by an ISP in India ?
Authority For Advance Rulings Seagate Singapore International Headquarters (P) Ltd., In Re Section 90, DTAA between India & Singapore, Art.
Section 90, Section 9
AAR : Whether the amounts received/receivable by Joint Stock Company Foreign Economic Association “Technopromexport” (‘applicant’ or ‘JSC Technopromexport’) from National Thermal Power Corporation Ltd. (‘NTPC’) under Contract No. CS9558-102-2-FC-COA-4520 dt. 25th March 2005 (‘offshore supply contract No. 4520’), for offshore supply of all plant and equipment including mandatory spares are liable to tax in India under the provisions of the IT Act, 1961 (Act) and the Agreement for Avoidance of Double Taxation between India and Russia (‘India-Russia tax treaty’)
Authority For Advance Rulings Joint Stock Company Foreign Economic Association “TECHNOPROMEXPORT”, In Re Section 9, 90, DTAA between India &
