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Cognizant Technology Solutions vs Commissioner Of Income Tax

In Verizon Communications Singapore PTE Ltd v. ITO (supra), the decision in the case of Poompuhar Shipping Corporation Limited v. ITO (supra), was relied upon, wherein for the purposes of determining whether the payments made constituted royalty, recourse was had to the meaning assigned to it _________________ Page 88 of 145 https://www.mhc.tn.gov.in/judis ( Uploaded on: 27/11/2025 06:25:48 pm ) TCA Nos.277 to 280 of 2016 by taking into consideration newly inserted Explanations 4 and 5 under the Finance Act, 2012.
Madras High Court Cites 102 - Cited by 0 - S Mohan - Full Document

Cognizant Technology Solutions vs Commissioner Of Income Tax

In Verizon Communications Singapore PTE Ltd v. ITO (supra), the decision in the case of Poompuhar Shipping Corporation Limited v. ITO (supra), was relied upon, wherein for _________________ Page 87 of 144 https://www.mhc.tn.gov.in/judis ( Uploaded on: 27/11/2025 06:07:17 pm ) TCA Nos.277 to 280 of 2016 the purposes of determining whether the payments made constituted royalty, recourse was had to the meaning assigned to it by taking into consideration newly inserted Explanations 4 and 5 under the Finance Act, 2012.
Madras High Court Cites 102 - Cited by 0 - S Mohan - Full Document

Verizon Communications Singapore Pte ... vs The Income Tax Officer on 7 November, 2013

38. Recently, in the case of M/s.Poompuhar Shipping Corporation Ltd., V. The Income Tax Officer, Chennai in T.C.(A)Nos.2206 to 2008 of 2006 concerning the case of time charter, this Court, by order dated 09.10.2013, considered the meaning of the expressions 'right to use' and 'equipment' and held that payment made for taking ship on time charter constituted 'royalty' as defined under Section 9(1)(vi) of the Income Tax Act. This Court considered the issue on use or right to use, particularly with reference to the term 'royalty' as defined under Explanation 2 and held that the expression 'use or right to use' is intended to take its ordinary meaning and applied in the broader sense, to mean employing for any purpose. Referring to the amendments made through insertion of Explanations 4 and 5, this Court held that the retrospective amendment has thus removed all doubts in so far as the expression 'use or right to use' to be understood in the context of possession, control or location.

M/S Cognizant Technology vs The Income Tax Officer (Tds) / on 28 April, 2026

In Verizon Communications Singapore PTE Ltd v. ITO (supra), the decision in the case of Poompuhar Shipping Corporation Limited v. ITO (2013) 38 taxmann.com 150 (Madras), was relied upon, wherein for the purposes of determining whether the payments made constituted royalty, recourse was had to the meaning assigned to it by taking into consideration newly inserted Explanations 4 and 5 under the Finance Act, 2012.

Cognizant Technology vs The Asst. Commr. Of Income Tax on 28 April, 2026

In Verizon Communications Singapore PTE Ltd v. ITO (supra), the decision in the case of Poompuhar Shipping Corporation Limited v. ITO (2013) 38 taxmann.com 150 (Madras), was relied upon, wherein for the purposes of determining whether the payments made constituted royalty, recourse was had to the meaning assigned to it by taking into consideration newly inserted Explanations 4 and 5 under the Finance Act, 2012.
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