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that Clause 17.1 of the purchase order, which is titled 'Assignment, Subcontracting', permits the buyer, viz., the plaintiff company, to assign or reassign

computed by applying a net profit rate of 8% after allowing Subcontracts, materials supplied, deductions such as Seignarage, Labour cess, VAT etc., depreciation, Interest ... Assessee further submit that there is no margin derived from to Subcontract works assigned. The Sub contract agreements were also submitted before you for verification

time. 24 ITA Nos.1479 & 691/Del/2016 Subsidiary may subcontract with third parties to perform some or all of such work upon MSFT ... such developments shall be and are hereby transferred, sold, conveyed and assigned to MSFT. To 25 ITA Nos.1479 & 691/Del/2016 the maximum

India) and onsite (i.e. at clients location). For onsite assignments of petitioner, the development of software is usually sub-contracted to the respective group ... customers. The overseas subsidiaries to whom the onsite work is subcontracted by the petitioner are tax residents of USA, Germany, Netherlands, UK, Singapore and China

Google India Private Limited, ... vs The Deputy Commissioner Of Income Tax ... on 11 May, 2018

M/S.Us Technology Resources P. Ltd, ... vs The Dcit, Trivandrum on 23 May, 2018

Zuberi Engineering Company, Jaipur vs Deputy Commissioner Of Income Tax, ... on 21 December, 2018 vk

M/S Sumeet Research And Holdings Pvt. ... vs M/S Sipra Appliances on 14 September

Pipavav Energy Pvt Ltd vs Madhavi Procon Pvt Ltd on 21 December, 2018 Equivalent citations

Ddit, New Delhi vs M/S. Western Union Financial Services ... on 28 September, 2018 ITA