Intertek India Private Ltd., vs State Of Karnataka on 2 August, 2012
Author: Anand Byrareddy
Bench: Anand Byrareddy
IN THE HIGH COURT OF KARNATAKA
CIRCUIT ... agreement available on record.
M/s Intertek India Private Limited, Goa, India
(Hereinafter referred to as 'Intertek', for brevity ) was identified
and nominated
quashed.
5
IN CRIMINALPETITION No.10513/2012
BETWEEN:
1. Intertek India Private Limited,
a company incorporated under the
Companies Act,1956 , having its office ... agreement available on record.
M/s Intertek India Private Limited, Goa, India
(Hereinafter referred to as 'Intertek', for brevity ) was identified
and nominated
quashed.
5
IN CRIMINALPETITION No.10513/2012
BETWEEN:
1. Intertek India Private Limited,
a company incorporated under the
Companies Act,1956 , having its office ... agreement available on record.
M/s Intertek India Private Limited, Goa, India
(Hereinafter referred to as 'Intertek', for brevity ) was identified
and nominated
quashed.
5
IN CRIMINALPETITION No.10513/2012
BETWEEN:
1. Intertek India Private Limited,
a company incorporated under the
Companies Act,1956 , having its office ... agreement available on record.
M/s Intertek India Private Limited, Goa, India
(Hereinafter referred to as 'Intertek', for brevity ) was identified
and nominated
between India and
Singapore, business income could not be taxed in India unless
assessee was having a P.E. in India. Particular reliance was placed ... decision of Authority for Advance Rulings in the case of
InterTek Testing Services India (Pvt) Ltd. [307 ITR 418 (AAR)], Bharti
AXA General Insurance
Solutions Ltd. Vs.ITO, [(2009) 122
TTJ 410 (Bang)];
iv) Intertek Testing Services India Pvt. Ltd. [(2008)
307 ITR 418 (AAR);
v) Worleyparsons Services ... source. Hence, this case is not
applicable at all.
iii) Intertek Testing Services India Pvt. Ltd. [(2008) 307 ITR 418
(AA)- Here in this case
fees for technical
services' under Article 13(4) of the India - UK Treaty, it was submitted that since the above
definition covered only technical ... DCIT (2003) 86 ITD 791 (Mum-Trib)
2. Intertek Testing Services India Private Limited (2008) 307 ITR 418 (AAR)
3. Diamond Services International
technical services and brought the same to tax in India.
19. The learned counsel appearing for the assessee
has relied on the following decisions ... Anapharm Inc., 305 ITR 394 (AAR).
4. Intertek Testing services India P. Ltd., 307 ITR 418
(AAR)
5. Ernst & Young
Beers India Minerals Pvt Ltd (Kar HC) - Sl No 3 of the
compilation
ITO V/s De Beers India Minerals Pvt Ltd (Blore ITAT ... compilation
Intertek Testing Services India (AAR) (307 ITR 418) - Sl No 9 of the
compilation
All the aforesaid cases deal with the aspect of what
would not be taxable in India for the simple
reason that it was not having any permanent establishment in India.
Further, according ... that of Authority for Advance Ruling in the case of Intertek
Testing Services India
