Krishi Rasayan Exports Pvt. Ltd., ... vs Acit, Rg-12, Kolkata, Kolkata on 8 March, 2017
appeal of
the Assessee, the only grievance projected by the Assessee is that there should not be
double exclusion
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1 - 10 of 223 (0.74 seconds)Hitt Holland Institute Of Traffic ... vs Ddit, International Taxation 1(1), ... on 8 February, 2017
contracts in India from the said PO. The project office has only been used to collect
money and pay certain expenses on behalf ... India-Netherlands Double Taxation Avoidance
Agreement (' DTAA'). The AO however held that the Assessee had a Project Office for
execution of GOK Project
Dcit, (It), Cir-1(1), Kolkata, Kolkata vs The Dongfang Electric Corporation, ... on 9 February, 2018
power
equipment, turnkey contracting for power projects, turnkey contracting for machinery,
electrical machinery, electronic equipment and related projects etc.' The assessee has its
sufficient ... business in India, through the project
office referred to as "Dongfang Electric Corporation Kolkata Project Office". Admittedly,
since the year
B.V. Van Oord Atlanta vs Asstt. Director Of Income Tax on 24 August, 2007
building site or construction, installation or assembly project constituted PE only when such site or project continued for a period of more than six months ... approval was mandatory for closure of a project office,
(iii) Books of account revealed that the project office was operating till
Hitt Holland Institute Of Traffic ... vs Acit, International Taxation, Circle - ... on 1 August, 2018
VATMS) system for ONGC (ONGC VATMS - AMC Project).
The transactions of the assessee are covered under the Double Taxation Avoidance
Agreement (DTAA) between India
Hitt Holland Institute Of Traffice ... vs Dcit, International Taxation 1(1), ... on 4 April, 2018
Mumbai, Chennai and Kolkata) Project ].
b) Establishment of Vessel Traffic Service (VTS) system in the Gulf of Kuchchh (GOK
Project)
c) Contract to provide Annual ... VATMS) system for ONGC (ONGC VATMS - AMC Project).
The transactions of the assessee are covered under the Double Taxation Avoidance
Agreement (DTAA) between India
Acit(It), Circle - 1(1), Kolkata , ... vs M/S. Gifford Llp, London on 12 February, 2020
assessee where it has attributed 10% of
total profit from the project for the work done to its PE in India.
• Therefore AO held that ... well as Article 5(2) of the India-UK Double Taxation Avoidance
Agreement (DTAA) for the relevant assessment year is without doubt and settled
Hitt, vs Dcit, International Taxation, ... on 20 July, 2018
Mumbai, Chennai and Kolkata) Project ].
b) Establishment of Vessel Traffic Service (VTS) system in the Gulf of Kuchchh (GOK
Project)
c) Contract to provide Annual ... VATMS) system for ONGC (ONGC VATMS - AMC Project).
The transactions of the assessee are covered under the Double Taxation Avoidance
Agreement (DTAA) between India
Dongfang Electric Corporation, ... vs Ddit (It)-1(1), Kolkata, Kolkata on 25 October, 2017
project office referred to as
"Dongfang Electric Corporation Kolkata Project Office". Admittedly,
since the year 2004 the said Kolkata Project Office has served ... book results of the Project Office which were arrived at in
consonance with Article 7(1) of Double Taxation Avoidance Agreement
between India and China
M/S. Utkal Builders Ltd., , ... vs Dcit, Circle - 1(1), Kolkata on 12 September, 2024
will tantamount to double
taxation on the sales and income of the same flats of the project which is
not permissible