2018
M/s. Shamrock Pharmachemi Pvt.Ltd.
reported in 327 ITR 456(SC) in support of his contentions apart from
the following decisions:-
(a) Decision ... Court in the
case of GE Technology Center Pvt.Ltd. in 327 ITR 456 (supra),
wherein the head notes of the said decisions are reproduced
issue in hand is directly70) 327 ITR 456(SC) covered by the decision of
Hon'ble Rajasthan High Court in the case
Court in the case of G.E. India Technology v. CIT
(327 ITR 456) vide order dated 10th September 2010 held as under ... India Technoology
Centre P Ltd vs CIT reported in 327 ITR 456_(SC) supports the case of
the assessee. This decision has been rendered after
matter of GE India Technology Centre P. Ltd v CIT (327 ITR 456). Copy of
the Order passed by the Hon'ble ITAT ... reported in (2010) 193 Taxman
234(SCT, (2010) 327 ITR 456 (SC) has interpreted the provisions of sec
195 of the Act and has held
case of GE India Technology
Centre Pvt Ltd v. CIT [327 ITR 456] wherein it is held that
only if, the payee is taxable ... case
of GE India Technology Centre Pvt Ltd v. CIT [327 ITR
456], I am of the considered view that
case
of GE Technological Centre Pvt. Ltd. v. CIT 327 ITR 456.
ITA No.351/Mds/2013 &
ITA Nos.316 & 317/Mds/2014 ... Bang)
• G.E. Technology Centre Pvt. Ltd., Vs. CIT (327 ITR 456)
8.2 We heard the rival submissions and perused the material placed on
record
ITR 305 (SC). It was also pleaded that the
decision in the case of G.E. India (327 ITR 456)(SC) favours
the case
India Technology Center (P). Ltd vs. CIT & Ors. (2010) 327
ITR 456 (SC)
"A person paying interest or any other ... Court in the case of GE India Technology Centre Pvt.
Ltd., 327 ITR 456. In this way, the ld.CIT(A) has deleted the
disallowance
that in the case
of GE India Technology Cen. P Ltd. (327 ITR 456(2010)(SC) it was
held that ... case of GE India Technology
Centre (P.) Ltd v. OT [2010] 327 ITR 456/193 Taxman 234, tax
deduction at source obligations under section
case of G E Technology Centre V. CIT , reported in 327 ITR 456(SC)."
5. Before the CIT(A),the assessee submitted that ... case of G E
Technology Centre v. CIT [2010] 327 ITR 456 (SC). Chargeability to tax
comes only when the income arises/ accrues in India
