registration
Professional Fee and
9. Hark Bahadur Rawal Individual Nepal Reimbursement of
1,50,000 Government Fee.
Tommy Hilfiger Professional Fee for
10. Europe ... Manike Professional Fee and
14. Firm Sri Lanka Reimbursement of
28,060 Government Fee
GDC Professional fees for
15. Nayanashantha Individual Sri Lanka Reinvestigations
training, etc.)
3. Business promotions, information 40,80,740
technology expenses, professional
fees, etc.
3,93,03,905
4. Since, the aforesaid payments were ... technical services nor for any
professional services; and
• lastly; coming to the reimbursement of expenses for professional
fees, on a perusal of the details
clearly make a
difference between "fees for technical services" and "fees for
professional services". He further put to our attention that ... kinds of the payments i.e. fees for technical services and
fees for professional services is a blurred and not judicially
recognised, it would lead
Deloitte Touche Tohmatsu, New Zealand has
rendered their professional services outside India. Therefore,
payment of professional fees cannot be said to accrue or arise ... Similarly, Deloitte & Touche, London has rendered their
professional services outside India. Therefore, payment of
professional fees cannot be said to accrue or arise
relation to
legal and professional fees.
4. Erred in making disallowance under Section 37 of the Act in respect
of legal and professional fees incurred ... transactions in connection with payment of brand
royalty and payment of professional fees and not accepting the
analysis undertaken by the Appellant to determine
professional services" because
none of the conditions as mentioned in the aforesaid Para of Article 14 is satisfied.
Once,the"professional fee ... professionals stayed in India for the period exceeding 183 days in any
consecutive twelve months period. Accordingly, under the DTAA the "professional fee
scrutiny proceedings, the Assessing Officer noticed certain
payments for professional fees to non-residents firms, on which
no tax was deducted at source. The services ... rendering
professional services is taxable in the country of its residence.
The Ld. CIT(A) also examined taxability of the professional fee
paid under Article
parties. It is an undisputed fact on the file that the professional fees shown
by the assessee in its P&L account far exceeds ... account and when the professional
income declared by the assessee far exceeds the professional fees shown in
the AIR information, then additions solely based
account of
reimbursements towards consultancy and professional fees
paid to group companies under section 40(a)(i) of the Act
5.1 On the Facts ... amounts paid to a group company towards reimbursement
of consultancy and professional fees on the ground that
appropriate taxes has not been with held under
remittances made for
Ph.d Thesis Evaluation, Faculty Development
Expenses and Professional Fees.
4.27. During the period, remittances have been
made for Ph. D Thesis ... Evaluation, Faculty Development
Expenses and Professional Fees. The remittances have
been made for the Evaluation of Ph. D Thesis submitted
to the experts
