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1 - 6 of 6 (0.32 seconds)The Income Tax Act, 1961
Section 37 in The Income Tax Act, 1961 [Entire Act]
Section 9 in The Income Tax Act, 1961 [Entire Act]
Steffen, Robertson And Kirsten ... vs Commissioner Of Income-Tax on 29 October, 1997
4.9 In the case of Steffen, Robertson and Kirsten Consulting
Engineers and Scientists vs. Commissioner of Income Tax. [1998]
230 ITR 0206 [Authority for Advance Ruling], the Hon'ble
Authority for Advance Ruling in its order dated 29.10.1997 held
that "the living allowance paid to the foreign. technicians will
form an integral part of the fees payable to SRK under the
agreement and will also be taxable in India."
Danfoss Industries P Ltd., Chennai vs Department Of Income Tax on 24 June, 2013
In Danfoss Industries P. Ltd. vs. Commissioner of Income
Tax [2004] 268 ITR 0001 [Authority for Advance Ruling], the
Hon'ble Authority in its order dated 14.05,2004 held that "the
payments to be made by the applicant pursuant to the agreement
proposed to be entered into between the said Danfoss Singapore
for the services to be provided by it to the applicant cannot be said
to be reimbursement of the actual expenditure incurred by
Danfoss Singapore and it cannot be said that no income is
embedded into such payment, therefore, the payments have to be
made after withholding tax under Section 195 of the Act."
4.11. The Authority for Advance Ruling again in the in the case
of Timken India Ltd. [2005] 273 ITR 0067 held:
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