Times article that 50 lac litres of ground water was extracted
daily by Tanker mafias with no action and a Times of India article dated ... litigation.
7. Reference may also be made to some other news items/articles. In
a recent news item dated 15.7.20203 in Tribune under the title
reported in 327ITR 456 (SC).
We find that as per Article 7 of UK and Singapore Treaty, in the absence
of PE in India ... case of GE India Technoology
Centre P Ltd vs CIT reported in 327 ITR 456_(SC) supports the case of
the assessee. This decision
K C Lakshman Rao vs M/O Railways on 30 September, 2020
OA 69/2017
attracted in the present case."
[emphasis supplied]
14. 2015 (327) E.L.T. 528 (Tri.- Mumbai)
24
C/51928/2018
31. The provisions ... sale of "Li Ning"
brand sports goods within India. Article 4 of the agreement
provided that the Distributor will make best endeavours
resident. [ Refer GE India Technology Centre (P) Ltd v. CIT : 327
ITR 456]. Further, if we consider the ambit of definition of
'royalty ... issue under
consideration is payment made towards software, which is a
copyrighted article/asset, it needs to be considered whether the
payment made
fundamental right to use loud-speakers or similar
instruments under Article 19 (1) (a) of the Constitution. On the
contrary, the use of such instruments ... Pollution Rules will be a violation of fundamental rights of
citizens under Article 21 of the Constitution as well as
fundamental right of citizens
Double Taxation Avoidance
Agreement between India and Netherland. He referred to article 11 of the agreement
and took us to clause 6 where the term ... interest" and therefore the article 11 does not
apply. He then took us to the article 12 of the DTAA and stated that
that no tax was liable to
be deducted at source as per Article 14 of DTAA with UAE on account of
payment to non-resident ... decision in the case of GE India Technology
Pvt. Ltd. 327 ITR 456 (SC). Further, it was stated that in any case the amount
ought to have appreciated as per the
provisions of Article 7 of the DTAA between India and
USA, the ratio of the decision ... case
of G.E.Technology Centre P Ltd v CIT 327 ITR 456 and the
clarification issued by the CBDT vide Instruction
No.02/2014
Smt. Aarti Singal, Chandigarh vs Dcit, Cc-1, Chandigarh on 7 February, 2020
आयकर अपील
