royalty' under Section 9 of the Act
read with the Double Taxation Avoidance Agreement
between India and United States of America?
(iv) Whether under ... deduction of tax at source considering the non
discrimination Article of the Double Taxation
Avoidance Agreement between India and United
States of America
royalty' under Section 9 of the Act
read with the Double Taxation Avoidance Agreement
between India and United States of America?
(iv) Whether under ... deduction of tax at source considering the non
discrimination Article of the Double Taxation
Avoidance Agreement between India and United
States of America
facts and circumstances of the case, the Tribunal was right in allowing double deduction without considering the principles laid down ... exemption and granting depreciation in addition would amount to a double benefit that has to be specifically conferred. He would rely on the judgment
behalf of the Revenue is that it
would amount to allowing a double deduction if the
provisions of Sections ... doubt
that a statute is normally not construed to provide for
a double benefit unless it is specifically so stipulated or
is clear from
Court reviewed
a large number of previous authorities on the concept of
double proof i.e. recovery from guarantors in the context
of insolvency proceedings ... function of the rule is not to
prevent a double proof of the same debt
against two separate estates (that is what
insolvency practitioners call
domestic law. The above view would be fortified, if there were a Double Taxation Avoidance Agreement (DTAA).
14. The Commissioner of Income Tax (Appeals ... liability under the domestic law. If there is also a Double Tax Avoidance Agreement, this inference is further buttressed, if they do not have permanent
work was treated as double duty for 252 days in a 12 calendar month and was
paid Rs.150/- per day, thus, his employment ... continuation thereof, he
worked for 135 days from 15.02.2006 to 14.07.2007 (double duty for 270 days) and
for 117 days from 15.02.2007 to 12.09.2007 (double
submitted that the Board has approved the erection of new 400KV double circute line newly constructed Rasipalayam 400KV sub-station to Salem for a route ... approved by considering the crossing of exiting 110KV double circuit EHT power line at crossing angle of 83 degrees as per Rule
observations made by the
Honorable Madras High Court that it had claimed double deduction in
AY 14-15. Assessee has failed to establish that ... part of any other amount allowable as deduction. Thus,
assessee has claimed double deduction and addition of Rs. 6,54,75,440/-
is being made
observations made by the
Honorable Madras High Court that it had claimed double deduction in
AY 14-15. Assessee has failed to establish that ... part of any other amount allowable as deduction. Thus,
assessee has claimed double deduction and addition of Rs. 6,54,75,440/-
is being made
