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The Commissioner Of Income Tax vs M/S Urban Ladder Hoime Decor Solutions ... on 7 February, 2025
cites
The Income Tax Act, 1961
Article 12 in Constitution of India [Constitution]
Section 194J in The Income Tax Act, 1961 [Entire Act]
Article 8 in Constitution of India [Constitution]
Section 5 in The Income Tax Act, 1961 [Entire Act]
Bmw India Financial Services Private ... vs Dcit, Circle-10(1), Delhi on 3 February, 2023
(b) Yahoo India (P) Ltd vs. DCIT (2011)(11
taxmann.com 431)(Mum)
In the above said two cases, the Tribunal held that
the amount paid by the assessee to M/s Google
Ireland Ltd for the services rendered for uploading
and display of banner advertisement on its portal
was in the nature of business profit on which no tax
is deductible at source, since the same was not
chargeable to tax in India in the absence of PE of
Google Ireland Ltd in India. Finally, the coordinate
bench held as under in the case of Right Florists:-
Motorola Inc., Erisson Radio Systems ... vs Deputy C.I.T. on 22 June, 2005
ITA No. 11 of 2022 c/w ITA No. 12 of 2022,
ITA No. 14 of 2022 & ITA No. 15 of 2022
India, and as held by a Special Bench of this
Tribunal in the case of Motorola Inc v. Dy.
CIT[2005] 95 ITD 269/147 Taxman 39
(Mag.) (Delhi) "DTAA is only an alternate
tax regime and not an exemption regime"
The Commissioner Of Income-Tax vs M/S Synopsis International Old Ltd., on 3 August, 2010
120. Fifthly, the finding that when a
copyrighted article is sold, the end-user gets the
right to use the intellectual property rights embodied
in the copyright which would therefore amount to
transfer of an exclusive right of the copyright owner
in the work, is also wholly incorrect. For all these
reasons, therefore, the judgment of the High Court
of Karnataka in Synopsis Intl. [CIT v. Synopsis
International Old Ltd., 2010 SCC OnLine Kar 5512]
also does not state the law correctly."