submitted that the case was regarding the claim under Section 84 (now Section 80J) and as the company was manufacturing pressure piles, it was held ... pillar and it could be considered as 'goods' or 'articles' but the same thing could not be said about dams
assessee will not involve manufacture or production of any article u/s 84 of the Act and words of that section were identical ... outsiders did not involve manufacture or production of any article as contemplated under section 84(2)(iii) of the Act as it stood in assessment
manufactures or produces any article or thing. He submitted that it is noteworthy to find that the word "article" or "thing ... articles. He also invited our attention towards the new entry 29A, which is added in Art. 366 of the Constitution of India, entry 84
Nokia Net Works Nokia Gruop Finland,, vs Dcit, New Delhi., on 5 June, 2018
IN
M/S. Voith Paper Gmbh, New Delhi vs Ddit, New Delhi on 21 February, 2020
section 9(1)(vi) of the
Act and Article 12(2) read with Article 12(3) (b) of the DTAA.
3.7. By above observations ... Fixed Place PE in India
under article 5(1) of the DTAA and a place of
management under Article 5(2)(a) of the DTAA
84,114 (being 10% of the net revenue
amount) during the AY 2013-14. Copy of Commissionaire Agreement
is attached at Pages 84 ... commission' income amounting to INR
24,84,114 (being 10% of the net revenue as per Article 4 of the
Commissionaire Agreement). Further, copy
total gross
receipts of Rs. 11,59,84,960/- of the appellant to be taxed
under Article 13 of DTAA between India and Norway
84,54,562
under section 9(1)(vii) of the
4. External consultants' services 3,07,307
Act and under Article ... 84,54,562/- on account
of Business Support Services being treated as FTS.
43. The ld. counsel for the assessee, referring to Article 12 (Royalties
fully automatized standard procedures.
bb. The Definition of Article 12A UN MC. While the headline
of Article 12A UN MC still reads 'technical services ... manner of providing services was not decisive (no. 84 UN MC
Comm. on Article 12A ). Examples in the commentary also follow
the wide understanding
