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1 - 5 of 5 (0.20 seconds)The Commr Of Income Tax vs M/S De Beers India Minerals Pvt Ltd on 15 March, 2012
In this
regard, it would be relevant to address the decision of Hon'ble
Karnataka High Court in the case of CIT vs De Beers India Minerals
(P) Ltd reported in 346 ITR 467 (Kar) to understand the meaning of
expression -'make available'. The relevant operative portion of the
judgement of Hon'ble Karnataka High Court is reproduced
hereunder:-
C.I.T-4 Mumbai vs M/S Kotak Securities Ltd on 29 March, 2016
In this regard,
analogy could be drawn from the decision of Hon'ble Supreme
Court the case of (CIT vs Kotak Securities Ltd reported in 383 ITR 1
(SC) wherein it was held that service made available by Bombay
Stock Exchange [BSE Online Trading (BOLT) System] 'for which
transaction charges are paid by members of BSE are common
services that every member of Stock Exchange is necessarily
required to avail of to carry out trading in securities in Stock
Exchange such services do not amount to technical services provided
by Stock Exchange, not being services specifically sought for by
user or consumer and, therefore, no TDS would be deductable under
section 194J on payments made for such services."
Engineering Analysis Centre Of ... vs The Commissioner Of Income Tax on 2 March, 2021
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The Order is downloaded from the DHC Server on 05/04/2024 at 21:24:30
elucidated by the Supreme Court in Engineering Analysis Centre of
Excellence Private Limited vs. Commissioner of Income Tax and
Anr. 6.
Macquarie Aerospace Finance 5092 ... vs Assistant Commissioner Of Income Tax ... on 16 March, 2022
5. The India-Netherlands Double Taxation Avoidance
Agreement 4 while speaking of 'fee for technical services' also
embodies the 'make available' clause. We note that insofar as the
aforesaid expression is concerned, we had in SFDC Ireland Limited
vs. Commissioner of Income Tax 5 observed as under: -
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