Dcit, Chennai vs Hyundai Motor India Limited, ... on 27 April, 2017
Dcit, Chennai vs Hyundai Motor India Limited, ... on 27 April, 2017
I.T.A. No
Search Results Page
Search Results
1 - 10 of 225 (2.00 seconds)Dcit, Chennai vs M/S. Cholamandalam Ms General ... on 26 August, 2022
other
contracting States and observed that re-insurance companies is
having PE in India, because in some cases the assessee has
made payment through insurance ... brokers which constitutes
agency PE and thus, the reinsurance companies are liable to
tax in India for their profits and consequently assessee is liable
Ford India Private Limited, ... vs Ito, Chennai on 31 January, 2017
India only if the enterprises carries on business in India
through PE situated in India and thus the assessee was not liable for
deduction ... service as per Income tax Act, there is no requirement for PE in India
and the same is taxable in India and hence the assessee
Deep Drilling 5 Pte Limited., Chennai vs Dcit, Intl, Tax 1(1),, Chennai on 7 February, 2022
company is a non-resident and doesn't have PE in India for the
3
year under consideration.
The Ld. AO ought to appreciate ... period of 183 days as it
6
required for considering as service PE in relation to FTS.
The Ld.AO ought to have appreciated
M/S. Cholamandalam Ms General ... vs Acit, Ltu-2,, Chennai on 21 August, 2024
other
contracting States and observed that re-insurance companies is
having PE in India, because in some cases the assessee has
made payment through insurance ... brokers which constitutes
agency PE and thus, the reinsurance companies are liable to
tax in India for their profits and consequently assessee is liable
Cholamandalam Ms General Insurance ... vs Dcit, Non Corp Circle 8, Chennai on 19 March, 2025
ceded to NRRIS with specific
clause excluding reinsurance from the purview of PE as per the DTAA
amounting ... business connection being established in
India towards such transactions.
ii. Agency PE - The remittance of the re-insurance premium
through the re-insurance brokers constitutes
Cholamandalam Ms General Insurance ... vs Dcit, Non Corp Ward 8, Chennai on 19 March, 2025
ceded to NRRIS with specific
clause excluding reinsurance from the purview of PE as per the DTAA
amounting ... business connection being established in
India towards such transactions.
ii. Agency PE - The remittance of the re-insurance premium
through the re-insurance brokers constitutes
Acit Ltu 2 , Chennai vs Cholamandalam Ms General Insurance ... on 21 August, 2024
other
contracting States and observed that re-insurance companies is
having PE in India, because in some cases the assessee has
made payment through insurance ... brokers which constitutes
agency PE and thus, the reinsurance companies are liable to
tax in India for their profits and consequently assessee is liable
Baggerwerken Decloedt En Zoon,Chennai vs Dcit International Taxation 1(1), ... on 25 February, 2025
information, arguments and evidence provided by the Appellant.
2. Constitution of PE by the Appellant
2.1. The lower authorities have, in the facts and circumstances ... case and in law, erred in concluding that Appellant has PE in
India based on conjectures and surmises, which are devoid of any
merits
M/S. Castlewick Fze,Dubai vs Acit,International Taxation, ... on 11 June, 2025
According to the assessee, it did not have any Permanent
Establishment (PE) in India and in absence of any income accruing or
arising in India ... purpose of such services and
the assessee does not have a PE in India.
4. The AO however rejected the contentions raised by the
assessee