Dcit, Cc-Ii, Chandigarh vs M/S Steel Strips Wheels Limited, ... on 27 May, 2019
olve d in a l l
the a p pe ... tate a n d a s pe
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1 - 10 of 10865 (1.39 seconds)M/S Sumitomo Corporation, New Delhi vs Dcit (International Taxation), New ... on 1 July, 2019
holding that the assessee did not have a Permanent
Establishment ('PE') in relation to various contracts for supplies and services
executed in India ... Assessing Officer
('AO') that the assessee had a fixed-place PE in India in relation to the
contracts for supplies executed
Honda Motor Co. Ltd., Noida vs Dcit (International Taxation), Noida on 10 May, 2019
erred in concluding that the Appellant had a
Permanent Establishment (PE) under Article 5 of the Indo-Japan
DTAA given the fact that necessary ... requisites of creating a PE
under Article 5 of DTAA were lacking in the present case.
3.1 That the AO/DRP erred in coming
M/S. Linklaters, Mumbai vs Ddit (I.T) - 3(2), Mumbai on 16 April, 2019
with regard to existence or otherwise of Permanent
Establishment (PE) of the assessee in India.
3. Brief facts are, the assessee, a partnership firm ... chargeable to tax in India in the
absence of a PE. In the course of assessment proceedings, the
Assessing Officer called upon the assessee
National Petroleum Construction ... vs Deputy Commissioner Of Income Tax, ... on 20 December, 2019
held to the contrary, observing that the
petitioner has no permanent establishment (PE) in India, and no income
earned from outside India activities will ... project office of the petitioner
did not constitute a fixed base PE under the provisions of the DTAA and in
absence thereof, the splitting
Bently Nevada Llc vs Income Tax Officer, Ward-1(1) (2), ... on 29 July, 2019
marketing activities were held attributable to a Permanent
Establishment („PE‟) of the Petitioner in India. Effectively, 2.625% of the
sales revenue was held ... profit attributable to the PE in India and this
was held to be taxable @ 40%. As a result, 1.054% of the gross sales
became
Hyatt International Southwest Asia ... vs Dcit (International Taxation), New ... on 4 December, 2019
erred in concluding that the Appellant has a
Permanent Establishment ('PE') in India under Article ... guidelines and parameters. The Appellant's
Employees visit India for Service PE under Article 5(2)(i) of the
Tax Treaty and even otherwise
Dcit, C-1(1), Chandigarh vs M/S Kamesh Bhargava Hospital & Research ... on 31 July, 2019
pe n a l ty p r ocee ... served th a t th e sc o pe
Dcit, Faridabad vs M/S. Nhpc Ltd., Faridabad on 8 May, 2019
2015
NHPC Ltd.
del eti ng di sall owance of prior pe ri od expenses of
Rs.3,89,59,508/- made by the Assessi ... Secti on 37(1) of the Act excl udes the pri or pe ri od
expenses while computing the taxabl e i ncome
Adit, New Delhi vs Nokia Corportion, Gurgaon on 29 March, 2019
India on the basis that the appellant has a
Permanent Establishment ("PE") in India under the
provisions of Article 5 of the Double ... auxiliary in nature
and therefore not excluded from the purview of
constituting PE under Article 5(4)(e) of the India-
Finland tax treaty