shrink-wrapped computer software, directly
imported from the United States of America [“USA”]. The assessment
years that we are concerned with ... Double Taxation Avoidance Agreement [“DTAA”],
between India and USA, and upon applying section 9(1)(vi) of the
Income Tax Act, found that what
Rajesh Tyagi & Ors. vs Jaibir Singh & Ors. on 8 January, 2021
Author: J
however held that such payments to the residents of UK and USA are not chargeable to tax keeping in view the provisions of the DTAAs ... alternate plea that in any case the payments made to residents of USA, UK, Israel, Netherlands, Singapore and Thailand could be taxed as business profits
according to the respondent, curious that
instead of returning to USA to submit to the jurisdiction of
competent court at the place where both ... obtained by the husband from a Court in the State of
Naveda (USA) fell for examination. This Court held that the
answer to the question
examined by Dr.
Ernest Greenberg of Sloan Kettering Memorial Hospital, New York, USA,
who opined that she was inoperable and should be treated only with ... VIth Amendment to the US Constitution.
It is submitted that Courts in USA have held that video conferencing does
not satisfy the requirements
Acit, New Delhi vs M/S Acb India Ltd.,, New Delhi on 17 January, 2018
working in the United States of America (hereinafter referred to
as the USA). The wife accompanied the husband to the USA on
17.07.2016. A daughter ... couple on 03.05.2017. She is a citizen of the USA. The
relationship between the husband and the wife got strained and
they made various allegations
jurisdiction. In fact, the evolving standard,
atleast as far as the USA and the UK Courts are concerned, is
to give greater importance ... that
case, the parties, who were American citizens, were
married in USA in 1933 and lived there till December
1946. But they had separated
qualify for exemption under Article 16 of the DTAA between India and USA on the ground that the assessee does not satisfy Clause ... DTAA between India and USA."
2. Since facts and issues involved are common and these appeals have been heard together, these are being disposed
married one Bhagyawanti at
Nagpur on 20.4.1967. The respondent later left for USA and
obtained an exparte divorce order against Bhagyawanti in the
trial court ... District Court, Nagpur and claimed that the decree obtained
by respondent in USA was void and based on misrepresentation
of facts and she claimed
