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Airport Authority Of India, New Delhi vs Ito (International Taxation), New ... on 5 September, 2023
cites
Section 9 in The Income Tax Act, 1961 [Entire Act]
The Commr Of Income Tax vs M/S De Beers India Minerals Pvt Ltd on 15 March, 2012
In De Beers India Minerals (P) Ltd.'s case (supra). Their Lordships posed
the question, as to what is meaning of make available to themselves, and
proceeded to deal with it as follows:
Ab Sciex Pte Ltd., Singapore vs Acit,Circle Int. Tax. 1(1)(1), New ... on 29 April, 2022
5.4 Romer Labs Singapore Pte. Ltd. Vs. ADIT, Tax Circle 2(1),
International Taxation 2013] 30 taxmann.com 362 (Delhi Trib.).
wherein the Hon'ble Tribunal has held as under:
Section 195 in The Income Tax Act, 1961 [Entire Act]
Infobip Limited, United Kingdom vs Assistant Commissioner Of Income Tax ... on 26 May, 2023
5.1 Infobip Ltd. Vs. Assistant Commissioner of Income Tax,
Circle (IT), 2 (1)(1) 2023] 150 taxmann.com 503 (Delhi - Trib),
wherein the Hon'ble Tribunal has held as under:
Section 248 in The Income Tax Act, 1961 [Entire Act]
Mahindra & Mahindra Ltd. vs Deputy Commissioner Of Income-Tax on 18 February, 1997
9.8 In Mahindra and Mahindra Ltd. v. Dy CIT [2009] 313
ITR (AT) 263 (Mumbai) (SB) it has been held that where the
payer only obtained the benefit from the services, but did not get
any technical knowledge experience or skill in its possession for
future use, it cannot be said that technical know-how was made
available.
Abb Switzerland Ltd. , Bangalore vs Dcit( International Taxation), Circle ... on 3 August, 2023
5.2 ABB Inc. v. DDIT International Taxation, Circle-1(1), [2015]
59 taxmann.com 159 (Bangalore-Trib.) wherein the Hon'ble
Tribunal has held as under
Outotec India Pvt. Ltd., New Delhi vs Addl. Cit, Special Range -7, New Delhi on 15 September, 2021
9.7 In Outotec India P Ltd. v. CIT [2015] 41 ITR (Trib.) 449
(Delhi), Delhi Bench of the Tribunal pointed out that the
expression "make available" in the context of 'fees for technical
services contemplates that the technical services should be of
such a nature, that the payer comes to possess the technical
knowledge so provided which enables it to utilize the same
thenceforward. If the services are consumed without leaving
anything tangible with the payer for use in future, it will not be
'make available' of the technical services notwithstanding the fact
that its benefit flowed directly to the payer.
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