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Fees for technical services

Section 10, Sec. 143(3), Sec. 144C, Section 10AA, Section 143, Section 144

Gujarat H.C : Whether the ITAT has erred in law in deleting the addition made by the Assessing Officer on account of upward adjustment to the arm’s length price adjustment of Rs. 1,48,43,000/= to the payment of technical services paid by assessee to its associated enterprise ?

Avijit Das / February 20, 2017

High Court Of Gujarat Pr. CIT vs. Woco Motherson Advanced Rubber Technologies Ltd. Section 10AA, 143(3), 144C Asst. Year 2011-2012 […]

S.C : The income from the use of Global Telecommunication Facility called ‘Maersk Net’ can be classified as income arising out of shipping business and not as fees for technical services

Avijit Das / February 17, 2017

Supreme Court Of India Director Of Income-Tax (IT)-I vs. A.P. Moller Maersk A S Section 9 A.K. Sikri And Abhay

Delhi H.C : The assessees from providing technical services to other airlines is covered by Articles 8(1) and 8(4) of the Double Taxation Avoidance Agreement between India and Germany, and by Articles 8(1) and 8(3) of the Double Taxation Avoidance Agreement between India and Netherlands

Avijit Das / January 25, 2017

High Court Of Delhi Director Of Income-Tax vs. KLM Royal Dutch Airlines Section 9 S. Ravindra Bhat And Najmi Waziri,

Sec. 40(a)(ia), Sec. 194J, Section 40

Karnataka H.C : The assessee was not liable to deduct tax at source under Section 194J of the Income Tax Act, 1961 in respect of transmission charges payable to the Karnataka Power Transmission Corporation Limited and State Load Despatching Centre

Avijit Das / August 9, 2016

High Court Of Karnataka ACIT, Circle-I, Gulbarga vs. Gulbarga Electricity Supply Co. Ltd. Section 194J, 40(a)(ia) Assessment Year 2009-10 Vineet

Sec. 194C, Sec. 194J, Sec. 201(1), Sec. 201(1A)

Delhi H.C : The “wheeling charges” paid by the Assessee, in the facts of this case, was deductable as it did not amount to “fees for technical services” within the meaning of Section 194J

Avijit Das / August 6, 2015

High Court Of Delhi CIT vs. Delhi Transco Ltd. Section 194C, 194J, 201(1), 201(1A) Asst. Year 2005-06 S. Muralidhar &

Section 9, Section 195

Madras H.C : the Tribunal was correct in deleting the disallowance made by the assessing officer towards export commission paid by the assessee to the non resident on which it failed to deduct tax at source

Avijit Das / August 25, 2014

High Court Of Madras CIT, Coimbatore Vs. Kikani Exports (P.) Ltd. Section : 9, 195 Assessment Year : 2008-09 R.

Bombay H.C : The payments received by the assessee-company from Fertilizer Corporation of India, Indian Petro Chemicals Corporation and J.K. Synthetics Ltd. under the various contracts are in the nature of technical service fees covered by the proviso to section 9(1)(vii) and are, therefore, exempt from tax

Avijit Das / August 8, 2014

High Court Of Bombay CIT, Bombay City â€“iii Vs. Montedison Of Italy Section : 9 S.C. Dharmadhikari And B.P. Colabawalla,

Section 80HHC, Sec. 37(1), Section 35AB

Madras H.C : The amount paid by the assessee to the foreign company pursuant to the collaboration agreement dated 8.12.1993 is in the nature of royalty, and not fee for technical know how

Avijit Das / August 5, 2014

High Court Of Madras CIT, Madurai Vs. Hitech Arai Ltd. Section 37(1), 35AB, 80HHC Assessment Years 1995-96 And 1997-98 To

Section 9, Sec. 40(a)(i), Section 195

Madras H.C : Service rendered by non-resident agent could at best be called as a service for completion of export commitment and would not fall within definition of fees for technical services

Avijit Das / July 22, 2014

High Court Of Madras CIT, Chennai Vs. Faizan Shoes (P.) Ltd. Section 9, 40(a)(i) And 195 Assessment Year 2009-10 R.

Section 35AB, Sec. 37(1), Section 37

S. C : Once section 35AB comes into play, then section 37(1) has no application

Avijit Das / September 6, 2012

Supreme Court Of India Drilcos (India) (P.) Ltd. Vs. CIT, Madras Assessment Year : 1993-94 Section : 35AB, 37(1) S.H.

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