letter dated 08.11.2012 that the contract does
not stipulate that any job/assignment related to the subject
supply contract will be done in India, even ... with the previous consent in
writing of the ONGC, sublet/subcontract, transfer or assign the
contract or any part thereof in any manner whatsoever. However
Global E-Business Operations Private ... vs Deputy Commissioner Of Income Tax, ... on 23 March, 2023
have also seen that though the assessee claimed that entire contract
was assigned to M/s IRL and it was acting only as agent ... Assessing
Officer from the accounts maintained by the assessee understood as
subcontracting of the contract to M/s IRL and held that the assessee
Steria India Ltd., Noida vs Addl.Cit, Speciaql Range-8, New Delhi on 28 September
Hns India Vsat Inc. vs Dy. Director Of Income-Tax (Delhi) on 13 May, 2005
work
of repairs and replacement of parts, and no technician was assigned
to India for consultancy or supervision of repairs. We are therefore of
the view ... accordance with Article 2 hereof.
1.3 Lufthansa Technik shall be entitled to subcontract repair and
overhaul of components in accordance with Article
Tata Consultancy Serrvices Limited, ... vs Dcit-1, Mumbai on 15 September, 2023
1
ITA 5199
Hitt Holland Institute Of Traffice ... vs Dcit, International Taxation 1(1), ... on 4 April, 2018
InfoTech
software. A certain portion of this contract was
subcontracted to ISSI in USA. Therefore, rather than
send its own technical experts and employees ... rolls and were taken on to
the rolls of ISSI and assigned to the contractual work
with Pratt & Whitney. This was done for operational
that while this company operates
under various revenue model as per the assignments i.e., proportional
completion method on rendering services, whereas the assessee charges ... other hand, submitted that presence of
outsourcing cost/subcontracting cost does not affect functional
comparability. Further, it reduces the operating margin of the company,
which
