access to their
customer base. As per the agreement, the assessee-company has
approached these Finance Companies to provide periodical access to
the data base ... finance companies only allow access to
information as discussed above and the contract between the parties is
regarding access to data base
Delhi on 16.09.2004 in the
case of M/s. Data Access (India) Ltd (DAIL) in connection with
contravention of the TDS provisions by that company ... large debt of Rs.81 crores due from M/s. Data Access America Inc.,
USA (DAUS) to the aforesaid company. It has also been
informed
access to their customer base.
As per the agreement, the assessee-company has approached these Finance
Companies to provide periodical access to the data base ... finance companies only allow access to information as discussed above
and the contract between the parties is regarding access to data base
Cheran Holdings Pvt.Ltd
earlier belonged to one M/s.Data Access India Ltd. M/s. DAIL
has received funds from its parent company situated ... India) Ltd., which in turn has received money from
M/s.Data Access America Inc. Further, on 19th August, 2004
Data Access (India) Ltd. transferred
cent. of its sales. In the circumstances, in
the absence of some data, it cannot be simply asserted that
the benefit of MSIL ... surmises or
conjectures. The Transfer Pricing Officer will need to access
data as regards the strength of the foreign associated
enterprise's brand
cent. of
its sales. In the circumstances, in the absence of some data, it
cannot be simply asserted that the benefit of MSIL ... surmises or conjectures. The Transfer Pricing
Officer will need to access data as regards the strength of the
foreign associated enterprise's brand
customer's premises through
which the customer has access to data on the speed and delivery of
the data and voice sent from ... customer's
premises through which the customer has access to data on the speed and
delivery of the data and voice sent from
held that any payment made to database owners
outside India for accessing such databases and the
services provided by such telecom operator to the
customers ... made. The Hon'ble Tribunal also held
that payments for accessing data is like reading a book
in a library which could
that were
geographically dispersed throughout the world for the
purposes of accessing business data exchange, video
conferencing or any other form of telecommunication. The
parties ... customer's premises through which
the customer has access to data on the speed and delivery
of the data and voice sent from
itself in the
business of providing telecommunication services, namely, cellular
services, data access services, etc. in various telecom circles in the
country. A survey ... visiting circle and he can make and receive voice calls and access
data and other services without any human intervention. Similarly,
when a customer travels
