shall be deemed to include-- (a) the granting of disability and double or triple indemnity accident benefits, if so provided in the contract of insurance
royalty as defined in Article 13 of the
'Double Taxation Avoidance Agreement' (DTAA) entered into between the
Government of United Kingdom ... follows the Organisation for Economic Cooperation and
Developmentās (OECD) Model of Double Taxation Convention. There are
various commentaries on Double Taxation Conventions. Celebrated among
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
resident principal and vice-versa.
Thus, there is no double taxation in the hands of the
holding company as income of the subsidiary ... Delhi, and that, consequently, Article 5 of the India U.S.
Double Taxation Avoidance Agreement of 1990 (hereinafter
referred to as DTAA) was attracted. Consequently
recipient is in the taxable territory. (13) In order to prevent double taxation or non-taxation of the supply of a service
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
assessee-company has received Rs.3.18
crores from M/s. Double Star Builders Pvt. Ltd., which belong
to Today group of cases ... that assessee-company
has received Rs.3.18 crores from M/s. Double Star Builders Pvt.
Ltd., which is the group concern
investment thereby
inviting disallowance of the depreciation on such capital expenditure
quoting double deduction. During the course of assessment
proceedings, the Society's council ... utilization in past
years, hence the same could not be termed as double claim of
depreciation. Hence the disallowance of the depreciation is not only
LINGARAJE URS, NO. 725/0, 2ND CROSS VISHWAMANAVA DOUBLE ROAD, KUVEMPU NAGAR, MYSORE KARNATAKA-570023 4. RAJEVLOCHANA S/O. V.V. VENKATESHIAH ... LINGARAJE URS, NO. 725/0, 2ND CROSS VISHWAMANAVA DOUBLE ROAD, KUVEMPU NAGAR, MYSORE KARNATAKA-570023 4. RAJEVLOCHANA S/O. V.V. VENKATESHIAH
which was made by the A.O on account of double digit
suppression.
4. The brief facts of the case as noted ... noted in the assessment order that there was apparently double-digit
suppression in the seized document at page 4 of SPM/ 1 which reflected certain