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1 - 10 of 48 (0.62 seconds)The Income Tax Act, 1961
Article 13 in Constitution of India [Constitution]
Dcm Ltd. vs Income-Tax Officer on 11 October, 1988
27. The facts in the present case, I am afraid, are certainly distinguishable at least on two counts. Firstly, in DCM's case there was transfer. In the present case, the Italian company, as a sub-licensor has granted the rights and sub-licence to use and practice the process in India.
Article 11 in Constitution of India [Constitution]
Article 8 in Constitution of India [Constitution]
Article 12 in Constitution of India [Constitution]
Article 7 in Constitution of India [Constitution]
Article 2 in Constitution of India [Constitution]
N.V. Philips vs Commissioner Of Income-Tax (No. 1) on 6 May, 1987
In case of N. V. Philips vs. CIT (supra) wherein the payments were held as the character of royalty. That agreement was as per general clauses of the IT Act and not as per DTAA as per art. 13.3 of the agreement. Therefore, the ratio of this case also does not help to the submission of the learned Departmental Representative. Likewise, other cases relied upon by the learned Departmental Representative are distinguishable on facts. Therefore, they are also not helpful to the Revenue.