Datamatics Financial Services Ltd. vs Jcit, Special Range-25 on 25 August, 2004
ix) Hyderabad Industries Ltd v. CIT (252 ITR 401)
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1 - 2 of 2 (0.28 seconds)Reliance Energy Ltd.,, Hyderabad vs Assessee on 14 February, 2007
He drew our attention to
the department Circular No.6436 dated 31.8.1992 which explains the
scope and effect of the amendment made in sec.10 (6A). As per 10(6A)
tax paid on income by way of Royalty or Fees for Technical Services
derived by a foreign company from government of India or an Indian
concern in pursuance of an agreement entered into after 31.3.1976 and
where the agreement relates to a matter included in the Industrial policy
for the time being in force and such agreement is in accordance with
that policy then the tax so paid is not an income in the hands of the non
resident. The assessee further stated that the industrial policy of Govt.
of India shows that the agreement falls under automatic approval
category and in fact Reserve Bank of India has granted approval for
payment of fees by its letter dated 14.10.1997. He relied on the
decision of Karnataka High Court in the case of Hyderabad Industries
Ltd. Vs. CIT (188 ITR 749).
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