time being approved in
this behalf by the Board;
(b) legal charges for drafting any agreement between the assessee
and any other person ... Purnarth Investment Advisers Pvt. Ltd., [A]
(i) by way of legal charges for drafting the Memorandum
and Articles of Association of the company
sale of loan application forms (c) old record pulping charges and (d) demand drafts payable written back, of the assessee bank do not form income ... share forms, sale of loan application forms, old record pulping charges, and demand draft payable written back during the year under consideration.
11. The learned
assessee had
paid Rs.2,84,150/- vide draft dated 02.07.1996 to the PMC towards development
charges. The CIT(A) noted that the permission
purposes of Demand Drafts and for making payments
against Demand Draft Commission is charged.
6. Incidental charges are collected from account holders which are
credited
manufacturing
segment; (ii) Allocation of Regional Headquarter Charges (RHQ Charges)
and (iii) Payment of Global Software Charges. Pursuant to the said order ... Allocation of the RHQ Charges - Adjustment of Rs.11,18,90,980/- and
(iii) Payment of Global Software Charges - Adjustment made in the first
round
Following his view taken for earlier
years, the AO notified the draft order including the entire amount
from both the streams as chargeable ... charges were covered
by clauses (a) and (b) of para 4 of Article 12 of the DTAA, as
against his stand in the draft order
Following his view taken for earlier
years, the AO notified the draft order including the entire amount
from both the streams as chargeable ... charges were covered
by clauses (a) and (b) of para 4 of Article 12 of the DTAA, as
against his stand in the draft order
Employees Secondment charges and Reimbursement of
expenses. The assessee challenged the draft order before the DRP.
The DRP issued enhancement notice in respect of disallowance ... Employees Secondment charges and
Reimbursement of expenses was not subject matter of the draft
order, still the Hon'ble High Court, considering the ambit
books of account of assessee. Similar was the remark with regard to charges
for legal services. The TPO also reiterated that ... made on account of payment of intra group service
charges.
6. The Assessing Officer issued draft assessment order to assessee
proposing the aforesaid adjustment, against
therefore, included Rs.12.88 crore in
the total income in the draft order. The assessee approached the
Dispute Resolution Panel (DRP), which held that ... received. The AO treated such Software
Maintenance service charges as Royalty in the draft order. The
assessee placed reliance on the judgment
