nature of 'Royalty' under the Act and the India-
Ireland Double Taxation Avoidance Agreement (`lndia-lreland Treaty')
stating that the issue ... Royalty' as per the Article 12 of the India Ireland Double Taxation
Avoidance Agreement.
11. Erred in not following the principle laid down
M/S Wipro Limited , Bnagalore vs Joint Commissioner Of Income Tax ... on 5 October, 2020
authority.
The contention of the assessee is that the assessee will be double taxed as
the AO has already completed the assessment ... available in law and the assessee
will not be subjected to double taxation for the A.Y. 2011-12. The AO is
directed to give
nature of 'Royalty' under art. 13(3) of the Double Taxation Avoidance agreement (DTAA) between India and Italy without appreciating that the consideration ... liable to tax @ 20 per cent as determined under the provisions of Double Tax Avoidance Agreement (DTAA) between India and Italy. The company preferred
Indian Income-tax Act read with the provisions of the Double Taxation Avoidance Agreements entered into between the Government of India and the Government ... taxable by virtue of the provisions of Article III of the Double Taxation Avoidance Agreement between France and India. The assessment was completed
respect of normal depreciation but it did not provide for depreciation for double shift and triple shift working. To that extent, there has been understatement ... straight line method not only for normal depreciation but also for double shift and triple shift working of the assets. Schedule XIV to the Companies
initially single yarn and cleared the same to their sister init for doubling after payment of appropriate duty. The doubled yarn was cleared ... condition No 16. There is no dispute on this point. The doubled yarn is returned to their factory for dyeing. The dyed yarn is cleared
assessee and in the light of article III of the Double Tax Avoidance Agreement between the Government of India and the Federal Republic of Germany ... provisions such as article III of the Agreement for avoidance of double taxation between India and Federal Republic of Germany, would come for consideration only
Technical
services („FTS‟) in terms of Article 13 of India-France Double Tax
Avoidance Agreement („the DTAA‟).
3.2 That the DRP/ assessing officer erred ... entity, a partnership firm
registered in France in terms of Indo French Double Taxation Avoidance
Agreement. This is as per AAR number
disallowed the
deduction/debit. This fact is important. It indicates the double standards
adopted by the Department.
11. The dispute in this batch of civil
