relied upon the
decision of authority for advance ruling in case of SKF Boilers
and dryers private limited wherein it has been held that
withholding ... further relied upon
the Advance Ruling in the case of SKF Boilers & Driers (P) Ltd.
wherein it has been held that withholding
should be with reference to the Controlled Transactions being Royalty paid by
SKF to its Parent Company and by Assessee himself to its related party
ruling of the
Hon'ble AAR in the case of SKF Boilers and Driers P. Ltd., 343 ITR 385
wherein it was ruled that ... also been not considered, and therefore the case of SKF
Boilers and Driers P. Ltd. is to be treated as per incuriam. Therefore, the
finding
reliance in the AAR's decision in SKF
Boilers is concerned, with respect to the decision ... decision of the Authority for
Advance Rulings in the case of 'SKF boilers and driers
ruling of the
Hon'ble AAR in the case of SKF Boilers and Driers P. Ltd., 343 ITR 385
wherein it was ruled that ... also been not considered, and therefore the case of SKF
Boilers and Driers P. Ltd. is to be treated as per incuriam. Therefore, the
finding
ruling of the
Authority for Advance Ruling in the case of SKF Boilers and Driers P.
Ltd. - where a proposition of law was laid down ... Officer relied on the decision of the AAR in the case of SKF Boilers and
Driers (P.) Ltd. (supra). I find that the Assessing Officer
failed in establishing as to how the cases of SKF Boilers & Driers of
AAR and Rajiv Malhotra, mentioned in the assessment order ... failed in
establishing as to how the cases of SKF Boilers and Driers Pvt. Ltd. of
AAR and Rajeev Malhotra , 284 ITR 564 mentioned
income. Therefore,
in view of the AAR decision in the case of SKF boilers and Dryers Private
Limited reported in 15 Taxman ... relying on the AAR
decision in the case of SKF Boilers and Dryers Put. Ltd. (supra). The
AR has also made the following written submissions
Veendeep Oiltek Exports, Navi Mumbai vs Cit (A) 25, Mumbai on 25 October, 2017
आयकर
Authority of Advance Rulings in the case of SKF Boilers and Dri ers (P.)
Ltd. (2012) 18 Taxmann 325 and Rajiv Malhotra ... Authority of Advance Rulings in the case of SKF Boilers and
Driers (P.) Ltd. (2012) 18 Taxmann 325 and Rajiv Malhotra
