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1 - 10 of 17 (0.38 seconds)Article 12 in Constitution of India [Constitution]
Section 37 in The Copyright Act, 1957 [Entire Act]
Section 14 in The Copyright Act, 1957 [Entire Act]
The Telecom Regulatory Authority Of India Act, 1997
The Income Tax Act, 1961
Section 9 in The Copyright Act, 1957 [Entire Act]
Deputy Director Of Income-Tax, ... vs Set Sattellite (Singapore) (Pte.) Ltd. on 20 April, 2007
2.7. That on the facts and circumstances of the case and
in law, the Ld. AO has erred in disregarding the decision
of Hon'ble Bombay High Court in the case of MSM Satellite
(Singapore) Pte Ltd [2019] 265 Taxmann 376 (Bom) and
the decisions of Hon'ble Mumbai Bench of ITAT in the case
of Dy. CIT v. Set India (P.) Ltd. (IT Appeal No. 4372 (Mum.)
Adit Cir 2(2), Mumbai vs Taj Tv Ltd, Mumbai on 23 December, 2016
and ADIT (IT) v. Taj TV Ltd. [2016] 72 taxmann.com
143/161 ITD 339 (Mum.) wherein it was held that
consideration received for the distribution of television
channels does not qualify as Royalty under the respective
tax treaties.
M/S Dit (International Taxation), ... vs M/S Morgan Stanley & Co. Inc on 9 July, 2007
3.3. Without prejudice to the above, that on the facts and
circumstances of the case and in law, the Ld. AO has
grossly erred in not considering binding circulars issued
by CBDT and in not following judicial pronouncements by
the Indian courts including that of Hon'ble SC in the case
of DIT (International Taxation), Mumbai v. Morgan Stanley
and Co. Inc. (292 ITR 416) (SC) wherein it was held that
where a PE has been remunerated at an arm's length, no
further attribution of profits can be done for such PE: