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1 - 10 of 12 (0.79 seconds)Section 234B in The Income Tax Act, 1961 [Entire Act]
Section 9 in The Income Tax Act, 1961 [Entire Act]
Article 3 in Constitution of India [Constitution]
The Income Tax Act, 1961
Section 271 in The Income Tax Act, 1961 [Entire Act]
Centrica India Offshore Pvt. Ltd New ... vs Commissioner Of Income Tax -I, New Delhi on 10 December, 2014
The assessee will be entitled to the exclusive benefit
without any consideration being payable. If any new, improved or changed
method of marking or manufacturing the licensee products which are
discovered by the licensee or any of its employees. Viewed from this
prospective, there is no doubt that the requirements make available Clause
also stand satisfied. The Ld. DR relied upon the decision of the Hon'ble Delhi
High Court in case of Centrica India Off Shore Vs. CIT(A) (2014) 364 ITR 336.
The Ld. DR also relied the decision of the AAR in the case of Intertek Testing
Services India Pvt. Ltd. (2008) 307 ITR 418. The Ld. DR further submitted that
the cases/decisions relied upon by the assessee are distinguishable on facts
and are delivered in the contest of make available provision and hence have not
reliefs to the present case, since it is covered under the provisions of Article
12(4) (A) of the DTAA. Accordingly, it is prayed that the order of the DRP be
sustained and the assessee's appeal be dismissed.