Morgan Stanley Mauritius Company Ltd, ... vs Assessee on 27 January, 2016
आयकर अपीलीय अिधकरण, 'एल' खंडपीठ मुबं ई
INCOME TAX APPELLATE TRIBUNAL,MUMBAI ... 1625/Mum/2014,िनधा रण वष /Assessment Year-2007-08
Morgan Stanley Mauritius Company DCIT (Intl. Taxation)-4(1)
Ltd., C/o., M/s. SRBC
Supreme Court in the case of DIT Vs Morgan Stanley
& Co. reported in [207] 292 ITR 416, wherein the Hon‟ble Supreme
Court after ... consider the judgment in Director of IT
(International Taxation) vs. Morgan Stanley & Co. Inc.
(supra). The appeals dealt with the DTAA between India
down by the Apex Court of India, in the case of
Morgan Stanley & Co. Inc. vs, DIT
The same principle has been followed ... Apex Court of India in the case of Morgan Stanley &
Co. Inc. vs, DIT, is misplaced. The Hon'ble Supreme Court in
this
Supreme Court, in the case of DIT Vs Morgan
Stanley & Co Ltd [(2007) 292 ITR 416 (SC)], and contends that, in the light ... Supreme
Court's judgment in the case of Morgan Stanley (supra) also, the transfer pricing
provision cannot apply on the facts of this case
decision of Honorable supreme court of India in case of Morgan
Stanley and honourable Delhi high court in case of E Funds. He referred ... back office operations. Honorable supreme court in
case of DIT V Morgan Stanley & co Inc. 292 ITR 416 (SC) in case of whether back
Supreme Court in the case of DIT vs. Morgan Stanley 292 ITR
416 (SC). He also submitted that survey operation was done
u/s 133A ... Supreme Court in
the case of DIT vs. Morgan Stanley (supra); relevant portion of
the said judgment is reproduced below:
24 J. Ray Mc Dermott
expenditure.
ii. We also rely on the decision in case of Morgan Stanley India
Securities (P) Limited (55 DTR 177) ITAT Mumbai. wherein ... ordinate Bench of
the Tribunal in the case of Morgan Stanley India Securities (P) Limited
v/s. ACIT, reported in (2011) 55 DTR 177 (Mumbai
contention is that another co-ordinate bench of
this tribunal in Morgan Stanley India Securities Pvt Ltd vs. ACIT- ITA
No.5072/Mum/2005 decided
settled
legal position, including by precedents in the cases of Morgan Stanley India
Securities Ltd Vs ACIT [(2011) 55 DTR 177 (Mum)] and DCIT
said to be a consumer of the Authority.
6. In Morgan Stanley Mutual Fund Vs. Kartick Das , (1994) 4 SCC 225, dealing with a person
