Mutt AIR 1954 SC 282 that there is no reason why the word 'property' (as used in Article
rate of 10% for fee for technical services is prescribed in Article
12 shall have to be deemed to include surcharge and since cess ... ACIT [2014] 62 SOT 282 (Mumbai)
In view of the above, the Ld. AR submitted that tax rate mentioned in
Article 12 of the India
gains from mutual
fund units were not taxable in India under Article 13(4) of India-Mauritius
DTAA.
• However, since the learned AO has considered ... redemption of mutual fund units is not taxable in India as
per Article 13(4) of India-Mauritius DTAA, the Assessee submits that long-
term
3530/Del/2015
PE, Service PE and dependent PE as per Article 5 of Indo-USA DTAA and
profits ... Article 12 of the DTAA. As regards the IPLC/link charges
amounting to Rs. 53,282,192/-, the Assessing Officer held that the same
assessee has placed reliance on CIT v. Max India Ltd. 295 ITR 282 (SC); CIT v. G.M. Mitral Stainless Steel ... ACIT and Ors. 293 ITR 548 (Bom). He also referred to an article of Shri V.S. Mani appearing in Volume 132 of the Taxman
Dcit, Circle-2(2), New Delhi vs Anant Raj Ltd., New Delhi on 27 November
person searched
that any money, bullion, jewellery or other valuable
article or thing or books of account or documents
seized belong to person other than ... Hyderabad vs. Settys Pharmaceuticals & Biologicals
Ltd. , (2015) 57 taxmann.com 282 (A.P.) in which it was held as
under :
"Recording of satisfaction
Water Supply
Company .Limited ('VIWSCL')] is to be taxed under Article 12 of the India-
Germany Double Taxation Avoidance Agreement ('tax treaty ... should be taxed under Article 12 (2)
of the tax treaty @ 10 % or under Article 12(5) read with Article 7 of the tax
treaty
2012,
5325/Del/2013& CO 265 to 269, 270 to 273,
282 to 286/Del/2011, 1/Del/2015 & 227/Del/2012
order ... duty to seize the books of
account, other documents, money, bullion, valuable articles,
etc., which are found as a result of the search
carried before the Tribunal, the Tribunal by its order in ITA No. 282/Del/2005 dated 19-4-2005 upheld the validity of initiation ... only business connection but also a PE in India as per Article 5 of Indo-UK Double Taxation Avoidance Agreement and hence the income