German Express Shipping Agency (I) ... vs Dcit Cen Cir 6(4), Mumbai on 6 March, 2019
IN THE INCOME TAX APPELLATE TRIBUNAL ... 4187/Mum/2016
(Assessment Year :2006-07 TO 2012-13)
M/s. German Express Vs. Deputy Commissioner of
Shipping Agency (I) P. Ltd., Income
German Remedies Ltd. vs Cce on 10 June, 2003
JUDGMENT
V.K. Agrawal, Member (T)
1. The appeal filed by M/s. German Remedies
Meerut-I vs M/S Indo German Brakes Linings (P) Ltd on 1 November, 2011
IN THE CUSTOMS, EXCISE & SERVICE TAX
APPELLATE TRIBUNAL
West ... Department Authorities?
CCE, Meerut-I Appellant
Vs.
M/s Indo German Brakes Linings (P) Ltd. Respondent
Appearance:
Appeared for Appellant : Shri S.R. Meena
German Remedies Ltd. vs Commissioner Of Customs And Central ... on 27 September, 2001
JUDGMENT
Gowri Shankar, Member (T)
1. After considering the application for stay ... consent of both sides, decided to take the appeal for disposal.
2. German Remedies Ltd., the appellant before us, deposited, in response to what
Avoidance of Double Taxation (AADT) executed between India and the Federal German Republic of Germany and that when no income chargeable ... that purpose it entered into a collaboration agreement with a German company M/s. Lugri Gmbh (for short foreign company) on 27/29th June
three agreements were delivered to Tata Ltd., London, by West German companies.
5. The AO was of the opinion that Expln ... sums paid by the assessee to Federal Republic of German companies. This was a matter of challenge before the CIT(A).
6. Before
A.P. Power Generation Corporation Ltd. vs The Assistant Commissioner Of I.T. on 7
hands of the assessee before us, under article
7 of the India German Double Taxation Avoidance Agreement [(1996) 223 ITR (Stat) 130;
Indo German ... held to be taxable, under article 11 of the Indo German
tax treaty. That is the issue sought to be agitated by before us, though
paid a technical
fees of Rs. 336150/- to one Dr. Thiele a German individual resident,
which falls under the provision of section ... Theile. He
submitted that services are provided by an individual, German
Resident, in nature of scientific services, no fixed base is available
recovery of the said amount by pursuing legal remedies in the German Courts. The German High Court pronounced its decision on 21st March ... copy of the said judgment dt. 21st March, 1986, rendered by the German Higher Regional Court has been placed at pages
