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Tube Investments of India Limited Represented by Its Vice President, T ...

Court : Chennai

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 2(24), 5, 9(1), 10A, 10A(1A), 10B, 28 to 43C, 43D, 44AC, 64, 72, 80, 80(IA), 80(IE), 143C, 145, 153, 192, 193, 194, 194A, 194C, 194C(1), 194D, 194G, 194H, 194I, 194J, 194LA, 195, 195(5), 195A, 197, 198, 199, 200, 200(1), 201, 201(1), 201(1A), 205, 206C, 221, 271C, 276B and 276BB; Hindu Women's Right to Property Act; Companies Act; Finance Act, 1983; Finance Act, 2007; Central Excises and Salt Act, 1944 - Sections 11D; Bombay Rents, Hotel and Lodging House Rates Control Act, 1947 - Sections 11(4); Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act (SARFAESI), 2002 - Sections 13(4), 17 and 17(2); Andhra Pradesh Shops and Establishments Act, 1966 - Sections 47(3); Payment of Gratuity Act, 1972; Partnership Act, 1932 -

Reported in : (2009)226CTR(Mad)313; [2009]185TAXMAN438(Mad)

submission.87. The contention comparing Section 40(a)(ia) with the proviso to Section 40A(3)(b) of the Act as introduced through Finance Act, 2007, can have no relevance, in as much as in the first place, the two substantive provisions are not … Section 9;(iii) 'professional services' shall have the same meaning as in Clause (a) of the Explanation to Section 194J;(iv) 'work' shall have the same meaning as in Explanation III to Section 194C;(v) 'rent' shall have the same

The Commissioner of Income-Tax and Others Vs. M/s. Vodafone South Ltd.

Court : Karnataka

Subject : Service Tax

and not to customers directly. The Service Tax Act has also recognized roaming services as taxable services the Finance Bill, 2007. (12) The entire system is to be monitored /managed by the highly skilled technical. A small … received or paid on account of this is not technical fees and does not fall under purview of Section 194J of the Act even when the Assessing Authority rightly treated the payment made by Vodafone South Limited to

The Commissioner of Income-Tax Vs. M/S Vodafone South Ltd

Court : Karnataka

Subject : Direct Taxation

and not to customers directly. The Service Tax Act has also recognized roaming services as taxable services the Finance Bill, 2007. (12) The entire system is to be monitored /managed by the highly skilled technical. A small … received or paid on account of this is not technical fees and does not fall under purview of Section 194J of the Act even when the Assessing Authority rightly treated the payment made by Vodafone South Limited to

Commissioner of Income Tax -xiii Vs. Rajinder Kumar

Court : Delhi

Subject : Direct Taxation

The assessee was asked to explain why disallowance should not be made under Section 40(a)(ia) as amended by Finance Act, 2008 with retrospective effect from 1st April, 2005. The assessee filed written submissions that they had not claimed … to March, 2007.7. The Commissioner of Income Tax (Appeals) upheld the said addition under Section 40(a)(ia) observing that Section 194J required deduction of tax at source either at the time of payment or at the time of credit

Engineering Analysis Centre Of Excellence Private Limited Vs. The Comm ...

Court : Supreme Court of India

Subject : Direct Taxation

in the case of Arun Kumar (supra). To overcome the above decision, the law has been amended by Finance Act, 2007 with retrospective effect from 1/4/2002. The retrospective amendment merely takes away the above argument, which was available to … merely clarificatory of the legal position as it always stood. Likewise, Notification No.21/2012 dated 13.06.2012, which deals with section 194J of the Income Tax Act, does no more than providing that a transferee is exempt from deducting TDS

Commissioner of Income Tax: Delhi -i Vs. Bharti Airtel Limited

Court : Delhi

Subject : Direct Taxation

dismissed in view of the authoritative pronouncement of the Supreme Court in Commissioner of Income Tax versus Alagendran Finance Limited, (2007) 293 ITR 1 (SC).2. Relevant facts in brief may be noticed. Return filed by the assessee … 2011 for failure to deduct TDS under Section 194H on free air time provided to distributors and under Section 194J on roaming charges paid to other network operators. The Commissioner invoked Section 40(a) (ia) to make the said … book profits were assessed at Rs.1724,82,75 449/- under Section 115JB of the Act.4. Subsequently, the Assessing Officer issued notice under Section 147 and an order

Commissioner of Income Tax-II Vs. M/s. Delhi Transco Ltd.

Court : Delhi

Subject : Direct Taxation

2002 and was to remain valid for a period of five years, that is, up to 31st March 2007. Commencement of proceedings 4. A survey was carried out in the business premises of DTL under Section 133-A … this case, was deductable as it did not amount to fees for technical services within the meaning of Section 194J of the Act.' The BPTA 2. The Respondent Delhi Transco Ltd. ( ˜DTL') entered into Bulk Power Transmission

The Commissioner of Income Tax and Another Vs. V.S. Dempo and Co. Pvt. ...

Court : Mumbai

Subject : Direct Taxation

is not relevant for our purpose. We are also not concerned with insertion of section 9A by the Finance Act 2015 with effect from 1st April, 2016. 19. By Chapter III, incomes which do not form part of … under sub-section (3) has been furnished before the 1st day of April, 2007, such order shall be made on or before the 31st day of … section 9; (iii) professional services shall have the same meaning as in clause (a) of the Explanation to section 194J; (iv) work shall have the same meaning as in Explanation III to section 194C; [(v) rent shall have

Commissioner of Income Tax Vs. Herbalife International India Pvt. Ltd.

Court : Delhi

Subject : Direct Taxation

payment made to residents and non-residents have to be the same. (b) Prior to its amendment by the Finance (No. 2) Act, 2004 Section 40 (a) (i) of the Act provided for disallowance of payments made to … document titled Application and Interpretation of Article 24(Non-Discrimination), Public discussion Draft, May 2007 did envisage deduction of tax while making payments to non-residents. It is … section 9; (iii) professional services shall have the same meaning as in clause (a) of the Explanation to section 194J; (iv) work shall have the same meaning as in Explanation III to section 194C; (ib) any sum paid